The Pensions Regulator has published its updated guidance on reporting duties and enforcement activity.  From 1 July, previously suspended reporting requirements will resume.

Schemes who have agreed a suspension of deficit repair contributions will need to submit a revised recovery plan or a report of missed contributions.

In addition, reporting obligations in relation to the following will resume:

Late valuations and where a recovery plan is not agreed

Delays in cash equivalent transfer quotations and payments

Failure to pay audited accounts

Formal reporting in relation to master-trusts.

The Pensions Regulator also reports that around 10% of pension schemes have agreed a temporary suspension or reduction of DRCs.  However, they anticipate that further request may continue as employers review their overall financial position three months after business activities stopped or were otherwise impacted by the pandemic.

The Pensions Regulator expects trustees to undertake due diligence on the employer's financial position before agreeing to an extension of a previous suspension or reduction or to an entirely new request.  

The Pensions Regulator has expanded on its previous guidance and expects trustees to have sight of any terms etc agreed as part of a refinancing and should seek similar protection of any deferred contributions to any lenders.   

In addition, the guidance sets out some of the questions which Trustees should be asking to understand any risks to the scheme and whether they need to take any additional action.

In terms of next steps, trustees who have agreed to a suspension or reduction of contributions needs to report this to tPR.