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Pensions Update

Scheme Governance: Trustee TKU “Three R’s” Initial Questionnaire

On 6 April this year, the Trustee Knowledge & Understanding (“TKU”) regulatory requirement for all trustee boards was developed further – the annual trustees’ chair statement must include an explanation as to how the trustee board meets the TKU requirements and that trustees’ combined knowledge and understanding enables them to carry out their trustee duties.

There is a significant amount of training available for trustees not least the Pensions Regulator’s own online toolkit (www.trusteetoolkit.thepensionsregulator.gov.uk) to assist trustees with developing their Pension Three R’s:

  • Regulations: The Law relating to Trusts and Pensions
  • Returns: The Basic Principles relating to the Investment of Assets
  • Rules: The Familiarity with own Scheme Documentation

The Irwin Mitchell Pensions Team members have a depth of experience in assisting trustee boards meeting the requirements and developing their skills including:

  • analysis of self-assessment questionnaires of knowledge and requirements against the Pension Regulator’s own Scope Document (areas of expected knowledge) for recordkeeping and development of related bespoke training plan;
  • bespoke training based on scheme documents and scheme timetables (e.g. funding and investment); 
  • seminars and newsletters; and
  • drafting of scheme familiarity documents.
Initial TKU Questionnaire for Trustee Board Members

The questions below are designed to instigate Trustee Board members’ initial considerations in respect of their TKU compliance and requirements and highlight where further development may be required. We recommend that the Trustee board members consider the queries as individuals and as a trustee board as a whole – particularly as most trustee boards are jointly and severally responsible for the actions of the trustee board as a whole.


    1. Has our TKU been assessed in line with the Regulator’s Code of Practice and related Scope document, currently covering:
    a. The law relating to pensions and trusts;
    b. The principles relating to pension scheme funding;
    c. The principles relating to investment of scheme assets? 
    2. Do we have copies of and are we familiar (‘conversant’) with the current scheme documentation including legal governing documents and other key papers? Key documents include:
    a. Governing Trust Deed and Rules together with any amending deeds and if appropriate trustee resolutions etc.
    b. Scheme booklets together with subsequent announcements to members.
    c. Trustee meeting minutes (preferably for at least the last three years).
    d. Last full actuarial valuation and annual updates together with schedule of contributions and if appropriate recovery plan.
    e. Statement of Funding Principles and Statement of Investment Principles.
    f. Annual Report and Accounts. 
    3. Are any ancillary documents available or required to accompany the Scheme’s governing documents such as:
    a. A balance of powers
    b. A discretions list
    c. A conversance guide 
    4. Has each trustee board member received copies of the Guidance from the Regulator (including the Guide for Pension Scheme Trustees) and been informed of other documents (including Codes of Practice) available? 
    5. Following the assessment of the TKU, is there an adequate training programme (and record keeping) in place for both the full trustee board and individuals? Is relevant training available for all requirements (including online e.g. trustee toolkit) to fit with trustees’ requests and requirements? 
    6. Are we regularly informed of any updates on pension issues? Examples of helpful sources are:
    a. Pensions Regulator’s mailing list
    b. National Association of Pension Funds
    c. Pension-specific publications e.g. Professional Pensions, Pensions Week, Pensions World
    d. Some advisers offer seminars and regular updates 
    7. Is there an adequate induction and training programme available to new trustee board members including provision of key documents and assessment of TKU requirements?

For further information about the new single tier pension and the abolition of contracting-out and for any assistance in amending your pension scheme rules and member literature in light of the changes please contact the Pensions Team at Irwin Mitchell.

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  • Lucy Herbert
  • Legal Adviser - Associate
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