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Global rules on foreign direct investment (FDI)
Cross-border acquisitions and investments increasingly trigger foreign direct investment (FDI) screening requirements.
United Kingdom | Publication | August 2024
This briefing is an updated version of our original April 2022 publication.
The DWP has published final form guidance on the staged approach to connection to pensions dashboards. The guidance sets out a staged timetable for schemes to connect, with the largest schemes being required to connect first. The timeline now runs from April 2025 to October 2026 and is based on the number of relevant scheme members at the scheme year end between April 1, 2023, and March 31, 2024. A detailed staging timetable is set out below.
If you have outsourced your pension arrangements to a third party DC master trust, a stakeholder plan or a group personal pension arrangement, the relevant provider is responsible for connection to the dashboard structure. Any providers operating group personal pension arrangements and stakeholder plans with 5,000 or more members across all such arrangements are to connect to the dashboard structure at the same time as the very largest pure DC master trusts in April 2025, with providers with smaller businesses going in by January 2026.
Subject to the size criteria below, all occupational pension schemes, whether open or closed to future accrual, remain under a duty to connect until every pension is in payment or bought out.
Schemes with fewer than 100 relevant members are not in the frame for connection yet. However, the DWP recognises that some trustees or managers of occupational schemes with fewer than 100 relevant members at their reference date may wish to voluntarily connect to the dashboard system. The DWP’s guidance signposts such schemes to the Pensions Dashboard Programme’s own website which will have guidance in due course.
Small schemes may still fall into the frame if they are open to new members and grow fast enough. If an occupational pension scheme came into existence on or after April 1, 2024, connection should occur by either six months from the end of the first scheme year, or the assigned date that applies to schemes of similar size and type as set out in the guidance, whichever is later.
See Top Tip 5 for how and when to count your members.
Schemes should by now be well advanced with their connection plans. That plan needs to cover:
Each scheme required to connect in the first wave has a dedicated staging deadline. Connection has to happen in a short window immediately before that deadline, with the details to be agreed with the Money and Pensions Service (MaPS). The bigger the scheme, the earlier you must complete the process. The big DC schemes are up first but the timetable is very fast.
Getting providers and advisers to deliver changes fast costs money and creates risk. Maximise the time you have to deliver your readiness plan by working out now when your scheme needs to connect and working backwards from there.
You are expected to work out the staging deadline for each of your schemes and get in touch with MaPS at the right time – you cannot rely on the Regulator or MaPS reminding you, although the Regulator does plan to run a series of warm-up letters.
There are two key bits of information you need first: the number of relevant members your scheme had on its reference date, and the category into which your scheme falls. Top Tip 5 explains how to work these out and determine your staging deadline.
You can also check your date using the Pensions Regulator’s updated guidance published on April 12, 2024, which includes a calculator for a scheme’s “connect by” date.
Staging deadlines for large schemes
Relevant members | Pure DC master trusts | DC AE | Other DC (including hybrid) | DB |
20,000+ | 30 April 2025 | 31 May 2025 | 31 May 2025 |
31 May 2025 |
5,000-19,999 | 31 May 2025 | 31 May 2025 | 30 June 2025 |
30 June 2025 |
2,500-4,999 | 31 August 2025 | 31 August 2025 | ||
1,500-2,499 | 30 September 2025 | 30 September 2025 | ||
1,000-1,499 | 30 June 2025 | 30 June 2025 | 30 November 2025 | 30 November 2025 |
Staging deadlines for medium schemes
Relevant members | Staging deadline | Relevant members | Staging deadline |
750-999 |
31 January 2026 |
195-249 | 30 June 2026 |
600-749 |
28 February 2026 |
155-194 | 31 July 2026 |
400-599 |
31 March 2026 |
125-154 | 31 August 2026 |
320-399 |
30 April 2026 |
100-124 | 30 September 2026 |
250-319 |
31 May 2026 |
Note: the tables above do not cover public sector schemes, collective defined contribution schemes, stakeholder schemes, personal pensions, group personal pension plans or benefits which have been bought out with annuities. They do cover schemes which have one or more buy-in contracts in place.
The date by which a formal deferral of the staging date could be sought has now passed. If trustees miss their scheme’s staging date, the DWP expects them to co-operate with the Pensions Dashboards Programme to find a new connection date. Missing the ultimate connection deadline of October 31, 2026, may result in enforcement action being taken by the Regulator.
Publication
Cross-border acquisitions and investments increasingly trigger foreign direct investment (FDI) screening requirements.
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