TPR CDC code consultation: PLSA submission

In January 2022 TPR published a consultation on its draft code for the authorisation and supervision of single and connected employer CDC schemes.

The code is based on the DC Master Trust authorisation regime and as such sets the bar high for potential sponsoring employers to enter the CDC market. We agree it is important that only the highest standard of CDC schemes should be authorised, due to the potential variability and volatility of member benefits, although there is a balance to be struck here with implementing a practical and workable regime for potential sponsoring employers.

We will continue to engage with both the regulator and DWP on the next steps for multi-employer and decumulation-only CDC models.