UK Pension Scheme Audits Under The Pensions Regulator and FCA Framework

UK pension arrangements operate within a dual regulatory environment governed by The Pensions Regulator (TPR) and the Financial Conduct Authority (FCA). Audit requirements, governance expectations, and reporting obligations vary depending on whether a pension arrangement is trust-based or contract-based, occupational or personal, and single-employer or multi-employer in structure.

Understanding how pension scheme audits sit within this regulatory framework is essential for trustees, employers, pension providers, and administrators.

The Dual Regulatory Landscape

The Pensions Regulator (TPR)

TPR regulates occupational pension schemes, including:

• Defined Benefit (DB) schemes

• Defined Contribution (DC) trust-based schemes

• Small Self-Administered Schemes (SSASs)

• Multi-employer schemes and authorised master trusts

These schemes are generally subject to statutory audit requirements under the Pensions Act 1995, unless a specific exemption applies.

Financial Conduct Authority (FCA)

The FCA regulates pension providers and administrators, including:

• Self-Invested Personal Pension (SIPP) operators

• Group Personal Pension (GPP) providers

• SSAS administrators operating as FCA-authorised firms

While FCA-regulated pension arrangements do not always require a “scheme audit” in the occupational sense, they remain subject to rigorous financial statement audits, client asset (CASS) rules, and conduct and capital adequacy requirements.

What Is a UK Pension Scheme Audit?

A pension scheme audit is an independent statutory audit of the scheme’s financial statements. Its purpose is to provide assurance that:

• The accounts give a true and fair view

• Contributions have been paid accurately and on time

• Scheme assets exist, are properly valued, and are appropriately safeguarded

For occupational pension schemes, audited accounts must generally be signed and submitted within seven months of the scheme year end.

Occupational Pension Schemes and Master Trusts (TPR-Regulated)

Single-Employer and Multi-Employer Schemes

Most DB and DC occupational pension schemes—whether sponsored by a single employer or multiple employers—are required to undergo an annual audit. Key areas of focus include:

• Employer and employee contributions

• Investment ownership and valuation

• Benefit payments, transfers, and pensions in payment

• Trustee governance and internal controls

Master Trusts

Authorised master trusts are subject to enhanced regulatory scrutiny. In addition to statutory audits, they must demonstrate:

• Ongoing financial sustainability

• Robust systems and controls

• Strong trustee oversight and administration governance

Audits of master trusts are typically complex due to transaction volumes, multiple participating employers, and reliance on third-party administrators and investment platforms.

FCA-Regulated Pension Arrangements

Self-Invested Personal Pensions (SIPPs)

SIPPs are personal pension arrangements regulated by the FCA rather than TPR. Although SIPPs are not occupational pension schemes:

• SIPP operators must prepare audited statutory accounts

• Client assets must be safeguarded in line with CASS requirements

• Non-standard and higher-risk investments increase audit and compliance complexity

Audit work in the SIPP environment often intersects with investment valuation, trustee arrangements, custody controls, and client money considerations.

Group Personal Pensions (GPPs)

GPPs are contract-based arrangements between individual members and FCA-regulated providers. There is no scheme audit in the trust-based sense; however:

• Providers remain subject to FCA supervision and audit

• Employers retain responsibility for accurate payroll deductions and timely contribution payments

Audit and assurance activity commonly focuses on payroll interfaces, contribution reconciliations, and governance oversight.

SSAS Pension Schemes and Administrators

SSASs are occupational pension schemes, typically administered by specialist professional administrators, many of whom are FCA-authorised. Audits of SSASs commonly focus on:

• Loans to sponsoring employers

• Property holdings and non-standard investments

• Connected-party transactions

• Compliance with scheme rules and HMRC requirements

The quality of records and controls maintained by the SSAS administrator is a key audit consideration.

Reporting and Regulatory Interaction

Auditors have statutory duties to report material breaches of law:

• To TPR for occupational schemes and master trusts

• To the FCA where issues relate to regulated firms, client assets, or conduct

This makes pension scheme audits a critical regulatory safeguard rather than a purely financial exercise.

Why Choose Spondoo for Pension Scheme Audits?

Spondoo provides specialist pension audit services across the full range of UK pension arrangements, including:

• TPR-regulated occupational pension schemes and master trusts

• SSAS pension schemes and professional administrators

• FCA-regulated SIPP and GPP providers

Our audits are designed to do more than meet statutory requirements. We work closely with trustees, employers, and pension providers to:

• Identify and resolve issues early

• Reduce regulatory and reporting risk

• Improve audit efficiency and clarity

• Deliver audits that stand up to scrutiny from both The Pensions Regulator and the FCA

Our team combines technical pension expertise with a practical, commercially aware approach, ensuring a responsive and reliable audit service tailored to complex pension environments.

Get in Touch

If you would like to discuss pension scheme audit requirements under The Pensions Regulator or FCA frameworks, or explore how Spondoo can support your scheme or pension operation, please get in touch.

Email: audit@spondoo.co.uk
Telephone: 02033 259 341

Our team will be happy to provide clear, practical guidance tailored to your pension arrangement.