Record-keeping: a consultation document - The Pensions Regulator

professional guidance on engagement with those involved with pensions
in the following areas:
• Assurance Reports on Internal Controls of Service Organisations
made available to third parties (AAF 01/06). In particular, the controls
specified for authorising and processing transactions and maintaining
financial and other records are relevant to measuring and improving
scheme records;
• the assessment of risk and the attention given to internal controls.
These are important features of good governance and in both the
corporate and not-for-profit sectors include a requirement for a
statement in annual reports. We suggest that similar requirements
should apply to pension schemes and that trustees should report on
the key risks and effectiveness of controls that they have ensured are
in place. When we review the internal controls code we will consider
strengthening our approach on reporting from being good practice to
something which should be reported on in the trustees’ annual report,
and which would therefore fall within the general review of auditors.
The controls over record-keeping would form an essential part of
such reports.
Question 15: Should an annual statement by trustees about key risks and
internal controls be included in the code of practice on internal controls?
Enforcement
6.15 Our regulatory approach will emphasise education and enabling. Hence
the proposals to measure and improve scheme records are
recommended as good practice. The regulator will not take enforcement
action against schemes which do not take up the regulator’s proposals.
The regulator will assess the position in 2009, in the light of further
dialogue and information gathering, with trustees, providers,
administrators and others.
6.16 In the meantime the regulator will consider the inclusion of data, our
proposed benchmark, reporting by trustees, and other administration
issues when we review our code of practice on internal controls.
Question 16:Do you think that education and enabling will be effective in
improving standards of record-keeping?
The Pensions Regulator: Record-keeping consultation document
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