Statutory Rule 2026 No. 151 makes a clear change to Northern Ireland's pensions regime. The Department for Communities made the Regulations on 30 July 2026 and brought them into force on 31 July 2026. They were also laid before the Assembly under section 102(5) of the Pension Schemes Act 2021, so Assembly approval is still required within six months of commencement. The central policy move is straightforward. The Regulations remove the rule that kept schemes used by employers with no connection to each other outside the collective money purchase regime. In plain terms, collective money purchase schemes, often described as CDC schemes, can now be set up for multiple unrelated employers in Northern Ireland, but only if they pass a more demanding authorisation and supervision framework.
Until now, the Northern Ireland collective money purchase framework mainly assumed either a single employer or employers within the same corporate or economic group. The 2026 Regulations now write both categories into the Pension Schemes Act 2021: single or connected employer schemes, and unconnected multiple employer schemes. That matters because large parts of the statute now apply differently depending on which type of scheme is involved. The Regulations also give a more detailed test for when employers count as connected. That includes recent voting control of at least 33 per cent, joint ventures, joint employment, certain transfers of active members and structures designed to mirror a single combined economic interest. For advisers and trustees, classification is no longer a drafting detail. It is the first gate, because it decides which rulebook applies.
Entry to the market for an unconnected multiple employer scheme is built around a stronger authorisation file. Applications to the Pensions Regulator must now include a business plan, the scheme's latest accounts, the scheme proprietor's audited accounts and, where the proprietor is funded by another undertaking, that funder's audited accounts. The accounts rule is set tightly: the drafting blocks reliance on group-account or small-entity shortcuts when the Regulator is assessing individual financial strength. A new statutory role, the scheme proprietor, sits at the centre of that test. Each unconnected scheme must have one, and only one, scheme proprietor. That person or entity must be a body corporate or a partnership with legal personality, must not also be a trustee, and must be liable for set-up costs, authorisation costs, running costs and key continuity costs if the scheme runs into difficulty. The application fee is £77,000, and authorisation can fall away if the scheme does not begin operating within 24 months of the Regulator receiving the application, subject to a possible six-week extension.
Financial sustainability is no longer framed only as having enough money in the scheme at a given point. For unconnected schemes, the Pensions Regulator must also decide whether the business strategy is sound. That shifts the test towards the commercial model behind the pension vehicle, including its income base, cost assumptions, funding arrangements, target market and the resilience of any outside financial backing. The business plan requirements are detailed. The plan must normally cover between three and five years and set out membership, contributions, income, expenditure, funding terms and succession planning if key funders step back. It must be reviewed at least once a year, revised after any significant change and also revised if a triggering event reduces the value of the financial resources supporting the scheme. Trustees must approve the plan, and the trustees must also have first call on the assets held to meet the statutory cost requirements. For providers, this moves business planning from background paperwork into the centre of the authorisation case.
Governance duties are also widened beyond trustees and scheme managers. For unconnected schemes, the fit and proper test can reach the scheme proprietor, anyone promoting or marketing the scheme, and senior financial and investment officers. In parallel, those people move into the significant events and notification regime. This is a broader view of who can affect member outcomes, and it reflects the fact that commercial decisions sit outside the trustee board in this model. The marketing rules are especially notable. The Regulator must be satisfied that no one has carried out unclear or misleading promotion without correction, and that the scheme has systems to keep future marketing clear. Trustees are barred from promoting or marketing the scheme, and they cannot act as the scheme's senior financial officer. Materials aimed at employers must explain, in clear terms, that investment performance can move, that benefit levels can change and that expected outcomes are not guaranteed. There must also be routes for feedback, complaints handling and reporting back into scheme governance.
Ongoing supervision is similarly expanded. Trustees of authorised unconnected schemes must send scheme accounts to the Pensions Regulator within two months of obtaining them. The scheme proprietor must send its own accounts, and any relevant funder accounts, within nine months of the end of the relevant financial year, or sooner if the Regulator gives an early notice after certain triggering events. Civil penalties can follow non-compliance. The list of significant events now reaches matters that would matter to any prudential supervisor: failure to hit business plan milestones, liquidity shortfalls, inability to meet running costs, failures in systems or communications, proposals to begin marketing, and concerns that promotion has been misleading. The risk notice regime is also extended so the Regulator can act directly against the scheme proprietor. In practical terms, the supervisory model now looks much more like an ongoing prudential framework than a one-off gateway test.
The continuity rules are one of the clearest examples of the Regulations being built for a multi-employer commercial model. New triggering events include insolvency of the scheme proprietor, the proprietor becoming unlikely to continue as a going concern in prescribed cases, and a decision by the proprietor to end its relationship with the scheme. The continuity strategy for an unconnected scheme must be prepared by the scheme proprietor rather than the trustees, but it still needs trustee approval. At the same time, the trustees must remain free to act when a scheme gets into difficulty. The legislation requires the Pensions Regulator to consider whether there are any constraints on the trustees' ability to pursue continuity option 3, which is conversion to a closed scheme, unless the statute requires option 1 instead. Put plainly, employers, members or the scheme proprietor must not be able to block that decision through consent rights or other contractual controls. During a triggering event period, administration charges are also capped by reference to the lower of the current and previous scheme year levels.
Technical rules on valuation, benefit adjustment and wind-up are also carried across into the new regime. Unconnected schemes must obtain an actuarial valuation within the first year of operating and then at least annually. The scheme rules must contain prescribed methods for valuing assets, setting the required amount and adjusting benefits, including rules for multi-annual reductions where cuts are spread over up to three benefit adjustment dates. For pensioners during wind-up, the Regulations create a periodic income mechanism so payments can continue while liabilities are being discharged. The 2026 instrument also redraws the wider statute book. The 2024 collective money purchase regulations are now largely confined to single or connected employer schemes, while the new Part 4 regime deals with unconnected schemes. Separately, the Pension Schemes Act (Northern Ireland) 2021 is amended so an unconnected collective money purchase scheme is not treated as a Master Trust for that Act, with special rules where a Master Trust contains a collective money purchase section. For employers, providers and advisers, the immediate question is not whether Northern Ireland permits multi-employer CDC in principle, because it now does. The practical test is whether a proposed scheme can meet the much heavier requirements on funding, governance, marketing, reporting and orderly exit. Those requirements are live from 31 July 2026, while Assembly approval remains outstanding under the six-month procedure.