Covid-19: Pensions Update 18 June 2020

This tracker produced by our Osborne Clarke Pension Team colleagues is a summary of the legal and regulatory developments arising out of the Covid-19 pandemic that will be of interest to the trustees and employers of occupational pension schemes. The tracker will be updated on a regular basis throughout the Covid-19 pandemic. This version relates to developments between 4 and 18 June 2020.

How to use the tracker: The tracker is divided into different subjects. The column on the left hand side of the table shows whether the development applies to defined benefit schemes (DB), defined contribution schemes (DC) or both (All).


Covid-19 related schemes, legislation and business insights





AllCoronavirus Job Retention Scheme

HMRC has released a paper confirming how the Coronavirus Job Retention Scheme (CJRS) is changing from 1 July 2020. Employers might also like to read our Insight on key actions to take in response to the changes.

HM Treasury has announced that parents on, for example, statutory maternity or paternity leave who return to work in the coming months will be eligible for the CJRS, even after the 10 June 2020 cut-off date, provided their employer has previously furloughed employees.

HMRC guidance notes relating to the CJRS have been updated to reflect the changes to the scheme from 1 July 2020 and other points. The different guidance notes are accessible on this webpage and you can see how each note has been updated by clicking on the “See all updates” link at the top of each document.

On 12 June 2020, HMRC looks to have replaced the “Work out 80% of your employees” wages to claim through the CJRS’ guidance with a new note: Steps to take before calculating your claim using the CJRS. This new note contains more detail around “flexible furlough” and includes a link to an example of how to calculate the amount to claim for an employee on flexible furlough and a link to updated calculation guidance.

The Department of Health and Social Care has published and updated guidance to help people who buy care and support through a direct payment to know how and when they can use the CJRS.



AllNew regulations

The Coronavirus Regulations have been amended to reflect the further relaxation of lockdown measures (for example, to introduce the concept of ‘linked’ households).

Business insights


AllInsights, webinars and briefings

Employers might like to look at our range of business insights and webinars on wider legal issues relating to the Covid-19 pandemic. These relate to areas such people and workforces, contracts (including force majeure and material adverse change events), corporate, real estate, dispute resolution (including impact on courts and tribunals), finance and funding, insolvency, competition and state aid, and regulation and compliance. You can also sign up for our regular Covid-19 legal briefing.

Employer clients might like to ask their usual Osborne Clarke contact for our guide: Exiting from lockdown – Key issues for UK employers.

Trustee clients might like to ask their usual Osborne Clarke contact for our governance checklist for trustees and template business continuity plan.

Regulatory and industry bodies



The Pensions Regulator – Guidance for trustees


DBDB scheme funding and investment

On 16 June 2020, TPR updated its DB scheme funding and investment guidance for trustees. Important changes have been made, for example, in the areas of: employer requests to suspend or reduce deficit reduction or future service contributions; valuations; DB transfers; and regulatory approach & reporting requirements. The changes to reporting requirements include changes in relation to missed contributions and agreements to suspend or reduce.

AllScheme administration

On 16 June 2020, TPR updated its guidance for trustees and for people running public service pension schemes to include new content on potentially vulnerable members who are not online or do not feel comfortable using the internet and e-mail, and additional content on reducing the burden on administrators.

The Pensions Regulator – Guidance for employers


AllAutomatic enrolment and DC pension contributions

On 15 June 2020, TPR updated its automatic enrolment and DC pension contributions guidance to take account of the changes being made to the CJRS from 1 July 2020. (We discuss the changes to the scheme in the first section of this tracker.)

DBDB scheme funding

On 16 June 2020, TPR updated its Covid-19 DB scheme funding guidance for employers to reflect changes it has made to its guidance for trustees (discussed below).

The Pensions Regulator – Guidance for providers


There are no new developments.


The Pensions Regulator – Other


AllReporting duties and enforcement activity

On 16 June 2020, TPR revised this update to confirm that most of the reporting requirements which were paused in response to Covid-19 will start to apply again on 1 July 2020. TPR also set out its approach to enforcement.

The Pension Protection Fund

AllThere are no new developments.

The Pensions Ombudsman

AllThere are no new developments.

The Department for Work and Pensions

AllThere are no new developments.

The Financial Conduct Authority


AllResponse to Covid-19 and expectations for 2020

On 4 June 2020, the FCA published a speech by Megan Butler, an executive director of Supervision, on the industry’s initial response to the Covid-19 pandemic and the FCA’s priorities and expectations for the wealth management and advice industry.

AllEmergency regulation and learning from the coronavirus crisis

On 10 June 2020, the FCA published a link to an interview with its interim chief executive, Chris Woolard, on the FCA’s response to Covid-19 and future business planning.



AllThere are no new developments.

Money & Pensions Service


AllCorporate Plan detailing key priorities and Covid-19 support

On 16 June 2020, the MaPS published its Corporate Plan for 2020/21, outlining its strategic priorities and immediate response to the Covid-19 pandemic.

Pensions Administration Standards Association and the Pensions and Lifetime Savings Association


AllCorporate Insolvency and Governance Bill

On 15 June 2020, the PLSA confirmed that it had written to Paul Scully MP, the parliamentary under-secretary of state at the Department of Business, Energy and Industrial Strategy, to express concern about the Corporate Insolvency and Governance Bill. One concern is that the proposed new company moratorium could affect the ability of DB trustees to recover unpaid deficit reduction contributions and the scheme’s position in any future insolvency.

The Information Commissioner’s Office

AllThere are no new developments.

The Pensions Advisory Service (TPAS)

AllThere are no new developments.

The Pensions Management Institute

AllThere are no new developments.

The Association of Professional Pension Trustees

AllThere are no new developments.

The Office for National Statistics

AllThere are no new developments.