Changes proposed to employer-related investment rules for master trusts

The Government is consulting on a proposal to switch ERI restrictions for large master trusts over to investments in the scheme funder or scheme strategist.

This forms part of a larger Department for Work and Pensions (DWP) consultation on facilitating investment in illiquid assets (see Further DWP proposals for DC schemes to invest in illiquid assets).

The proposed changes would only apply to the largest master trusts (500 employers or more).

Changing the restrictions so that they no longer apply to the many employers in a master trust would remove the significant burden of having to track investment in each of the employers. This also recognises that when the ERI rules were originally implemented it was not with master trusts in mind.

However, trustees of master trusts should note the proposal to include the scheme funder or strategist within the ambit of the restrictions for the first time. Depending on the profile of the funder or strategist, some master trusts may find there is a still a need for careful tracking of investments.

The DWP proposes that these changes would come into force from October 1, 2022. Trustees of master trusts should monitor developments and update processes if necessary once any new regulations are settled.