On September 8, 2021, the Department of Work and Pensions began its consultation on the proposed drafting of regulations in relation to the Pensions Regulator’s ‘notifiable events’ regime.
The proposed changes included the introduction of two new employer-related notifiable events, an amendment to an existing employer-related notifiable event and the deletion of an existing employer-related notifiable event.
In addition to the above, the consultation also proposed a new and complex two-stage process for notifying the Pensions Regulator in respect of the two new notifiable events and the amended event. Please see our previous briefing,
Changes to the Pensions Regulator’s mandatory notifications regime dated September 22, 2021, for more information in respect of the proposed changes.
We have been keeping a close eye on any developments following the conclusion of the DWP’s consultation on October 27, 2021, and after an extended period, we now have an update. The Financial Services Regulatory Initiatives Forum, which is responsible for publishing the Regulatory Initiatives Grid (a consolidated document setting out planned regulatory initiatives relevant to the financial services sector for the next 24 months), has posted its newest version of the Grid, dated April 2025.
Annexed to the Grid is a list of the initiatives that were included in previous versions of the Grid but have now been ‘completed or stopped’. Contained within this section of the April 2025 Grid is the ‘Notifiable Events Code’ - “TPR consultation on expectations and approach to revised Notifiable Events legislation”. Although there has been no formal confirmation yet from the DWP, this is the latest indication that the Government and Regulators do not intend to progress with the proposed changes to the notifiable events framework.
In addition, the Pension Regulator’s Corporate Plan 2024 to 2027 (published in May 2024) contains no reference to the proposed changes to the notifiable events regime, which could be viewed as further indication that the proposed changes are no longer going ahead. Previous versions of the Pension Regulator’s Corporate Plan, such as the 2022 to 2024 version (published in June 2022) did contain reference to the proposed changes, stating “timing is yet to be confirmed but they will become operational in due course”.
The 2023 Regulatory Initiative Grid (the preceding version) listed the proposed changes to the notifiable events framework as an initiative, however stated that there were “no milestones added due to significant uncertainty around delivery”.
This outcome is not entirely unexpected as there was much industry criticism of the proposals. Whilst we will continue to monitor any further developments, including any official announcement from the DWP, we recommend that sponsoring employers of pension schemes continue to follow the current notifiable events framework, in respect of any corporate activity.
