Making the new Code manageable

Barnett Waddingham is helping trustees navigate their way through the requirements set out in The Pension Regulator’s draft new Code of Practice which is expected to come into force in summer 2022.*


*Update Dec 2022: As you probably know, the timing of the new Code has slipped since this video was released.  We now eagerly anticipate its publication in early 2023.


While we support the overall aims of the new Code (now know as the General Code), we recognise that it can be hard for trustees to know where to start on their journey towards compliance. It will also be important that whatever trustees do in relation to the new Code adds value to the future running of their scheme.

Many trustees will be in the uncomfortable position of needing to do a considerable amount of work within a limited timeframe (see 86% of trustees need to make significant changes). The complication is we aren’t yet completely sure what all that work will be as we are still awaiting the final outcome of the Regulator’s new Code consultation. To make sure they meet the requirements trustees need to start work now, but understandably will want to minimise any unnecessary work because the requirements in the final Code might be different from those in the draft.

So how can trustees get started in a way that adds value but avoids unnecessary work?

Barnett Waddingham has produced an Effective System of Governance (ESOG) framework document to help trustees home in on what needs to be done to be new Code compliant, and where to best focus their efforts now. The framework is purposely flexible enough to accommodate all types of pension scheme – large or small, DB or DC – but in all cases will allow trustees to document their ESOG in a way that is proportionate to their scheme. Once complete trustees will then be able to focus their efforts on 'filling in the gaps', starting with those governance items that are of most importance to them.

Please watch our short video to find out more.

If you would like to discuss how we can help you, please contact your usual Barnett Waddingham contact, Barbara-Ann Thompson or Sara Cook.

Preparing for the new Code of Practice

We explain TPR's guidance to better scheme governance results and achieve greater outcomes for members. 

Download our briefing note

The General Code

The Pensions Regulator sets out its expectations in relation to both ESOGs and Own Risk Assessments (ORAs) in the General Code.

Find out more