The Pensions Regulator has put a fresh warning out to trustees, urging them to check if they fall under master trust legislation.
The regulator has said that it is the trustee’s responsibility to check whether its scheme comes under the definition of a master trust, and if so, must apply to be authorised or trigger to exit the market by the 31 March deadline.
It comes as its latest market figures show that the number of schemes who have triggered to exit the market and who are expected to apply for authorisation has fluctuated, due to the trustees assessing the structure of their scheme.
TPR executive director of frontline regulation, Nicola Parish, said: “It’s really important that scheme trustees use our guide and seek additional advice if they need to, or they could find themselves being forced to wind up in four months’ time.
“From April 2019, for schemes which already exist in the market and haven’t applied for authorisation, there is no appeal process, no opportunity to file an application - no other option than to wind up.”
TPR said it has been working closely with the schemes it thinks meets the definition, and has also issued a step-by-step guide for schemes to check.
According to the regulator, schemes could potentially be master trusts if they are a defined contribution scheme providing pensions for multiple of unconnected employers.
Current market figures show that 90 master trusts have been identified in the market, with 32 schemes already triggering their exit from the market, down on the 33 from last month, while the number of schemes which have exited remain at three.
TPR said that one of the schemes who triggered their exit from the market restructured its scheme so that it “no longer met the definition of a master trust”.
Furthermore, the number of schemes who are expected to apply for authorisation has increased from 53 to 54.
The regulator has received just one master trust application since the new legislation around the fit and proper running of schemes came into force on 1 October.