TPR’s code of practice for CDC schemes was laid before parliament this week (29 April), ahead of coming into force around October this year.

The regulator also published its response to the CDC code consultation, which closed earlier this year, and stated that it would hold trustees accountable for poor communications. This was an area highlighted by many consultation respondents as needing clarification.

“Trustees have an important role in challenging key promotional materials… On the rare occasion trustees may not have identified issues, we do reserve the right to also take action against them.”

TPR consultation response

“As the trustees are prohibited from undertaking any of these activities, the responsibility would sit with the scheme proprietor and/or any other person they have delegated this responsibility to,” TPR stated.

“Trustees have an important role in challenging key promotional materials if they believe they are unclear or misleading, or both. On the rare occasion trustees may not have identified issues, we do reserve the right to also take action against them.”

The regulator also tightened up some wording around inducements and promotions in response to concerns raised.

An evolving regulatory approach to CDC

In its consultation response, TPR said it was “committed to a pragmatic regulatory approach” that will develop as the CDC market evolves.

The code has been expanded to include multi-employer schemes, with the first schemes expected to come into operation from early 2027, according to the regulator. It will be amended again once the government finalises retirement-only CDC rules.

TPR said it was already in discussions with “several possible market entrants”. TPT Retirement Solutions has already declared its intention to launch a CDC scheme.

Paul Eagles, head of CDC at TPT, said: “The CDC code being laid in parliament marks an important milestone in bringing multi-employer CDC to the UK market. It reflects the constructive engagement between TPR and the broader industry, and provides a positive step for schemes to move forward with confidence.

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