The general code one year on – a pivotal moment for trustees

15 July 2025

Back in spring 2024, The Pensions Regulator (TPR) introduced the general code of practice, consolidating several existing codes of practice into a single modular code. As a reminder, the general code contains 51 individual modules within five sections, and introduces three new important areas:

1. Effective system of governance (ESOG)

Trustees must establish, monitor and maintain an effective governance framework for their scheme. The ESOG, which should be proportionate to the size and complexity of the scheme, gives trustees oversight of day-to-day operations and helps demonstrates a well-run scheme.

2. Own risk assessment (ORA)

Schemes with 100 members or more need to carry out and document an ORA every three years and update it following any major change to the ESOG.

In the ORA, trustees will review and assess the effectiveness of their governance framework. They should then outline any changes needed to help further mitigate risk.

The first report will be due 12 months after the first full scheme year after the general code came into force. For example, if your year end is 31 March, your first ORA will be due by 31 March 2026.

3. Risk management function

Trustees of schemes with more than 100 members are also required to have a risk management function in place. The risk management function will regularly review key risks and report to the trustees as part of their oversight of the scheme’s governance framework.

The pivotal point – Where trustees should be now

By now, trustees should have completed their gap analysis, outlining what is already in place and identifying what more is required for compliance.

A plan should be in place with all the actions needed to bridge the gap between current practices and compliance. And trustees should be well on their way to closing those gaps and finalising new policies and processes.

This is a pivotal point of general code compliance. It draws to a close the steps required to establish and demonstrate that the scheme has an ESOG. Trustees should then make plans for ongoing compliance.

Trustees should now begin preparing for their first ORA using the information gathered so far. It’s important to remember that this will likely be a significant task and that the ORA deadline will come around fast, so shouldn’t be left to the last minute.

While TPR has not stipulated that outputs need to be made public or published online, they will be able to request sight of the ORA should they wish.

We understand that this is yet another project to undertake, with likely additional costs. However, it’s important to remember that by improving your governance framework, you can mitigate risks and safeguard your members. This in itself may yield other benefits – for example, by identifying any data issues and taking steps to correct them.

Our recent general code case study demonstrates that schemes can make broader gains rather than simply undergo a tick-box compliance exercise.

Has your scheme fallen behind? If you haven’t quite reached this pivotal point, don’t worry – it’s not impossible to catch up. But you do need to take action now. Read on to discover how First Actuarial and its Client Hub can make lighter work of general code compliance projects.

The general code and First Actuarial’s Client Hub

As many First Actuarial clients will be aware, we’ve developed a Client Hub to help you with the processes and documentation needed to run an effective scheme.

We’ve updated our Client Hub to help you meet the requirements of the general code, with these capabilities:

• ESOG – The Governance tile of the Client Hub now provides an ESOG area, with a range of tools to help you record and manage your ESOG, including monitoring and reporting tools.
• Gap analysis – Once you’ve populated the Client Hub with your key policies and documents, you can generate a gap analysis at the click of a button. If your scheme has yet to reach the pivotal moment I’ve just described, this may reassure you that it’s not too late. In our case study, we describe how we helped establish and document a new governance framework for trustees keen to comply with the general code, in only two months.
• Documentation – With the Client Hub, you can link policy documents, additional information and evidence to each individual module of the general code. In our case study, we discuss the raft of documentation that can be stored centrally in the Client Hub, saving trustees time when documenting evidence for their ESOG. The Client Hub will also map the finalised documents to the various modules of the code.
• Prompts and reminders – The Client Hub allows you to add review dates, prompts and reminders, alongside all your policy documents and evidence. This will help you make sure you’re reviewing elements of your governance framework at the right times.
• Ongoing monitoring and reporting – The new ESOG section of the Client Hub provides the tools to monitor and report on compliance, as the general code requires.

In summary, you can store your documents on the Client Hub, then use the Governance tile to produce outputs like the gap analysis instantly – a significant time-saver. This will help you stay organised, as you’ll always know where the latest versions are and when items are due for review. And crucially, it will keep all that information secure.

How else can we help you with the general code?

Alongside the capabilities of the Client Hub, our consultants can give you the support you need to meet the general code requirements:

• Training – We can provide trustee training to take you through what you’ll need to do to meet the requirements of the general code and why.
• Gap analysis – We can then help you with the gap analysis, to identify what’s needed to close the gap between existing practices and general code requirements.
• Policies and documentation – We can work closely with you from that point to produce or update any additional policies and documentation needed.

Our aim is to make this work as easy and efficient as possible for you. We lighten the load for you while giving you full control over your own policies.

Our approach is:

• Collaborative – We work in an incremental way, getting agreement at every stage of drafting.
• Proportionate – Together, we agree on proportionate approaches, based on the specific attributes of the scheme and First Actuarial guidance.
• Clear – We identify areas of focus and map policies and documents to the various elements of the code.
• Realistic – We take care to consider the impact of any changes on the actual running of the scheme, to make sure they’re feasible and realistic.
• Future-proofed – We look beyond the implementation of general code changes, and make sure we help you meet ongoing monitoring and reporting requirements.

What trustees should do now

I can’t overemphasise that if you have yet to complete your gap analysis and put a plan in place on how to meet the requirements of the general code, you must do that now.

The deadline for your first ORA will come around quickly for those schemes required to prepare one, and you need to start preparing for it as soon as possible.
We are here to help, especially if you feel that your scheme is falling behind. So do get in touch if you need any guidance on what you should do next.