Since the publication of the revised DB Funding and Investment Strategy Regulations at the end of January, schemes and their advisers have been eagerly awaiting an update on the other piece of the jigsaw - the Pensions Regulator's DB Funding Code.   Speaking at the PLSA Investment conference, Louise Davey (TPR's Interim Director of Policy, Analysis and Advice) confirmed that the Code will be published “this summer” and laid before Parliament, coming into effect in time for the first valuations under the new Regulations (from 23 September 2024 onwards).  She also advised that the parameters for “fast track” valuations will be published around the same time as the Code.

Ms Davey also announced that there will be a consultation exercise, beginning “in the next few weeks” on the statement of strategy, with a further consultation exercise to follow “later in the summer” on “covenant governance”.  In relation to the statement of strategy, whilst the Regulations set out the information to be included , the form and submission process are to be specified by TPR so we would expect this to form part of the consultation exercise.  In relation to employer covenant, the new regime requires a closer scrutiny of the employer covenant and the reliance that can be placed on it, so schemes and employers will be watching closely for TPR's guidance on how to approach this.

Eagle eyed observers will have spotted that the DWP published an updated draft of the DB Funding and Investment Strategy Regulations earlier this week.  The updated Regulations supersede the previous draft and make small changes to draft Regulation 20, which operates to amend the underlying Scheme Funding Regulations 2005, clarifying that the new regime applies in respect of valuations with an effective date on or after 23 September 2024.  The updated draft Regulations are still due to come become law on 6 April 2024.  For our thoughts on the draft Regulations and the actions for trustees and sponsors please see our article (which predates this latest small change)


Whilst its great to have an update on timescales, many in the industry might have been hoping for the updated Code to as soon as possible.  With two further consultations in the offing, its clear there is still thinking to be done before the new regime takes effect in September.  Given the draft Code will need to lay before Parliament for 40 days, and with the Parliamentary summer recess provisionally due to begin on 23 July 2024, we would hope to see it published no later than early - mid June.