The Pensions Regulator (TPR) has published an interim response to its March 2024 consultation on the format and requirements for the new statement of strategy that will be required for all actuarial valuations with an effective date on or after 22 September 2024.
TPR has also stated that it will publish a fuller response to the consultation before the end of the year.
The interim response provides illustrative ‘statement of strategy’ templates for schemes in four different circumstances, along with a data list that provides definitions and other information about the items that are required to complete the statement.
TPR notes that respondents to the consultation were broadly supportive of having pre-defined templates for the statement of strategy but with many suggesting a more proportionate approach be taken, with a typical scheme providing less information to TPR than proposed in the consultation.
In light of this feedback TPR is making a number of changes to its approach that will reduce the amount of information that it asks for in many cases. These changes include:
TPR has determined that the statement of strategy must be submitted in digital form. The interim response notes that schemes will not be able to submit a statement of strategy until TPR’s new digital service has been enabled, which is expected to be in spring 2025. TPR has confirmed that it will not treat it as a breach if submission of the statement of strategy or other valuation documents is delayed by its digital service not being enabled.
For valuations with an effective date before 22 September 2024, schemes should continue to submit information and documentation to TPR using the existing process, via its online Exchange service.