The Financial Sector Conduct Authority published a communication on 6 March 2020 aimed at pension funds who have no remaining members and still have historical outstanding actuarial valuation report submissions and outstanding annual financial statement submissions.

The purpose of the communication is to set out the process to be followed by these pension funds in order to achieve compliance with the regulatory requirements.

The process includes the submission of:

  1. a consolidated report which consists of a combination of statutory submission reports for a number of reporting periods into a single report;
  2. a consolidated valuation report which considers significant movements or releases since the previously submitted statutory actuarial valuation as well as build-ups of any reserves held; and
  3. consolidated financial statements which consider the period from the last submitted financial statements until the effective transfer date.

Each of these reports have specific considerations outlined by the FSCA that must be adhered to by a pension fund prior to submitting them.

Any pension fund intending to apply the consolidated process referred to in the Communication, is required to approach the FSCA before 30 June 2020, in order to commit to an action plan. The FSCA has outlined that it will consider waiving penalties relating to outstanding actuarial valuation report submissions.

However, it must be noted that all submissions of consolidated valuation reports and financial statements must be made prior to 30 April 2021 and no consolidated submissions outlined in the Communication will be accepted after that date.

Where there is no appropriately constituted board of trustees, the FSCA will write to the board, requiring it to properly constitute itself within 90 days. Where the fund cannot constitute a board, or fails to comply with the notice, the FSCA may appoint persons to constitute the board, and assign to them specific duties.

For further information regarding the Communication, pension funds are urged to contact Giulia Tognon at


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