If the pressure is rising on your general code compliance programme, now is the time to take stock.
Many occupational pension schemes are required to complete their first Own Risk Assessment (ORA) by 31 March 2026 or 5 April 2026. If your scheme’s ORA is due in Spring 2026, is your progress going according to plan?
The ORA is an assessment of how well the scheme’s Effective System of Governance (ESOG) is working and the way potential risks are managed. The ESOG needs to be complete for the ORA to be fully carried out. Our recently issued factsheet contains helpful suggestions on how the first ORA could be approached.
The Pressure Gauge
Are you on track to complete the ESOG on time? Where do you sit on our pressure gauge? This will impact your approach to the ORA in the coming months.
RED – Our scheme has not made significant progress with the ESOG
There could be many reasons why the scheme has not made good progress. For example, the trustees may have expected to reach full buyout this year, but the timetable has slipped.
Have the trustees taken legal advice on a proportionate approach to compliance with the general code? If not, consider doing so now. Establish a realistic plan for completing the ESOG and make this a priority in the coming months. Can you find extra resource or ask key advisers to assist? For example, we have template policy documents that can be adapted for your scheme, to help move your compliance project along quickly.
Seek legal advice if your ESOG cannot be completed before the ORA deadline and keep a clear audit trail to evidence that progress is being made.
AMBER – Our scheme is making good progress on the ESOG – it should be completed early in 2026
The trustees are well positioned and have the opportunity to devote sufficient time to the ORA in order for it to add value to the scheme. We expect that the ORA will take a minimum of a few weeks (in terms of planning, discussing and recording).
Trustees should begin making plans for the ORA this Autumn, including a timetable, so that work can begin as soon as the ESOG is complete. Consult the ORA module in the general code and consider whether trustee training or a facilitated workshop would help to kick start the process. Decide who will carry out the ORA and make sure that the right resources will be available.
GREEN – Our scheme’s ESOG is in place/almost in place
Consider starting the ORA this Autumn and spread the work out over the coming months so that steady progress can be made without the ORA competing for attention with other scheme priorities. If anything unexpected is found during the ORA, this may impact upon the trustees’ risk management objectives going forwards. Maintain an ESOG log and a policy review timetable to keep control and ensure that a rolling programme of general code compliance becomes part of “business as usual” activity.
Reduce Pressure
Taking stock this Autumn will turn the pressure dial down. With six months to go there is still time to make good progress and ensure that trustees are comfortable with the outcome of the first ORA. Contact us if you need any help with your general code compliance project.
