Further to my post a little while ago, I have just finished my first read through of the DWP document issued today, catchily entitled:
“Automatic enrolment: Guidance on certifying money purchase pension schemes and the money purchase element of hybrid schemes”
I must admit I was hopeful before I opened the document that it would represent a nice, clear, clean, approach to scheme certification. Bluntly, it doesn’t.
The final certification process seems to be designed to appease as many parties as possible, and as with any decision by committee ends up looking and feeling rather too complex. The step by step guide to certification at the back of the document highlights this, with no less 13 steps for the employer to consider in the process.
On the plus side, the additional complexity will probably allow many more employers to utilise a certified scheme for some, or all, of their employees than was originally envisaged, so it’s not all bad news.
There is far too much technical detail for me to absorb before I can commit to writing further on this, but one important point to highlight is that the certification process will now definitely be on a self-certified basis. The employer is responsible for certifying a scheme, and each certificate must be renewed (and indeed reviewed) at least every 18 months.
From the complexity of what I have read so far though, I suspect many employers will be keen for the actual work around certification to be undertaken by (or with) their professional pension advisers to avoid any inadvertent breach of the rules here.
And this is only one of the two DWP documents out today, I have now got to read the other one. It’s not all work, work, work you know…
Best regards
Steve
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