The Pensions Regulator’s (TPR) revised code of practice for collective defined contribution (CDC) pension funds has been broadly welcomed, but industry players are calling for fine-tuning to reduce remaining uncertainty.
Launched in December, the consultation set out how TPR plans to authorise and supervise multi-employer CDC schemes, expanding on its existing single-employer framework. The revised code reflects government regulations published in October, expected to take effect at the end of July 2026, alongside TPR’s finalised guidance.
The proposals aim to open the market to third-party providers, setting expectations around governance, investment, communications, and the fitness and propriety of those running pension funds.
Paul Waters, partner and head of DC markets at Hymans Robertson, said a single code covering both single and multi-employer CDC “should be easier to maintain over time and provides a clearer framework as the market develops”.
He added that the detail in the draft would help scheme providers prepare for authorisation, but cautioned that clarity and proportionality would be “critical” in areas such as investment strategy, sectionalisation and defining “significant events”.
Waters welcomed TPR’s recognition that systems will not be “fully built and tested” at authorisation.
“This is a proportionate and realistic approach. Starting from scratch gives schemes an advantage in terms of streamlined, efficient, digital-first member administration,” he said, noting, however, that successful implementation will require “significant up-front work, strong governance and experience in delivery”.
TPT Retirement Solutions welcomed TPR’s collaborative approach and described the draft code as a critical step for bringing multi-employer CDC schemes to the UK.
It highlighted areas needing more clarity, including what counts as a notifiable change to investment strategy and how fit and proper requirements apply to those marketing schemes.
CDC Forum co-chair Hari Mann said the draft code sensibly draws on established approaches, such as those for DC master trusts, while recognising the “distinctive features of CDC”, including actuarial governance, benefit uncertainty, and member communications.
LCP described the draft code as a key step ahead of the July 2026 deadline, but raised concerns that it appears to assume all schemes will be commercial, potentially limiting not-for-profit models.
Steven Taylor, partner and head of CDC at LCP, said it was important to recognise structures where financial resources may already sit within a trust. Donna Matteucci, senior consultant, added that clearer guidance would help non-commercial schemes demonstrate financial adequacy.
The Association of Consulting Actuaries (ACA) also welcomed the draft code but highlighted areas needing more clarity.
Chintan Gandhi, ACA honorary secretary, noted that promotional activity between schemes and employers is inevitable and any carve-out from marketing requirements should be justified in authorisation applications.
ACA also flagged that the code appears more restrictive than legislation on investment strategy changes and suggested aligning more closely to avoid over-sectionalisation.
Robbie Tink, senior consulting actuary and CDC working group lead at Barnett Waddingham, stressed that early confidence from employers and members will be vital to CDC’s success.
“A strong authorisation and supervision regime is essential to build this trust and ensure protections are in place for members, while being supportive of innovation,” he said.
