An event must be notified in writing to the Pensions Regulator as soon as reasonably practicable. It is important that events are notified quickly in order to act as an effective early warning of calls on the Pension Protection Fund. What is reasonably practicable depends on the circumstances. In all cases however it implies urgency. For example, where a trustee is made aware of a notifiable event on a Sunday, the Regulator should be notified on Monday.
The requirement to notify as soon as reasonably practicable is likely to mean that procedures for notification will be necessary outside the usual framework for considering pensions issues such as trustees' quarterly meetings. Procedures should also be put in place to require those such as administrators working on behalf of trustees and employers to alert trustees and employers quickly to notifiable events.
The events are intended to be relatively straightforward to identify; it should not be necessary to seek professional or expert advice on whether an event has occurred. There is no expectation that the decision to notify should require a special meeting of the trustees.
The events are worded to make clear when they should be notified. In some cases the duty to notify arises before the actual event has taken place. For example, when an employer decides not to pay in full a debt it owes to the scheme, the notifiable event is when the decision is taken by the employer's decision-making body, such as its board of directors, rather than implementation of the payment itself.
In other cases events may not be able to be notified until after they have taken place, for example a change in credit rating.