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The Pensions Regulator

Codes of practice

Codes of practice

Code of practice 09
Internal controls

A proportionate approach

  1. All schemes, unless exempt, are required to have adequate internal controls. Trustees must decide what internal controls are needed to satisfy themselves that the scheme is being well managed in accordance with the law and the scheme rules.
  2. Not all risks will have the same potential impact or the same likelihood of materialising. Trustees will need to look at both these areas and assess which risks the scheme can absorb without the need to take further action, and which risks require adequate internal controls to reduce their incidence and impact.
  3. When considering risk, trustees should be mindful of the nature of their scheme and the risks which are inherent in a particular structure. Smaller schemes may require less formalised controls than more complex larger schemes, but regardless of size, key risk areas will still need to be adequately controlled.

Related documents
Code of practice 09: Internal controls (PDF)
Related pages
Supporting guidance to be read in conjunction with the code: Internal controls guidance