• Connection compliance. It will also look at situations where a scheme fails to find a member’s pension and where the schemes concerned fail to provide data in line with their legal requirements.
• Audit trails. Schemes are expected to comply with the Regulator’s single code, once finalised, and maintain clear audit trails of the steps they take in resolving any issues arising. They should also keep records of the steps they take in data improvement.
• Non-compliance. The Regulator has various options for schemes that do not comply with their duties, including compliance notices and fines. The consultation paper includes several examples, and the Regulator’s proposed action in each case.

The Pensions Dashboards Regulations 2022 (see item 8 above) introduce new duties on trustees and scheme managers to enable dashboards to function and new powers for the Regulator to regulate these duties. Trustees should keep “clear audit trails” of the steps they take to comply with their duties, as well as keeping records of compliance, steps taken to resolve issues with third parties, their matching policy and steps taken to improve their data. The consultation will close on February 24, 2023, with the Regulator’s final policy due to be published in Spring 2023.