The Pensions Regulator (TPR) has published its final response to its Statement of Strategy consultation and announced plans to launch a 'submit a scheme valuation' digital service, which trustees will use to complete and submit their Statement of Strategy.

The consultation, launched in March last year, set out measures designed to support trustees in planning and managing their defined benefit (DB) scheme funding over the long term, as required under the new DB Funding regime.

Under the requirements, trustees are asked to complete a statement of strategy alongside their actuarial valuation, which sets out this long-term funding strategy and their approach to managing associated risks.

TPR previously confirmed, however, that it would share statement of strategy templates to minimise the administrative burden on trustees, including separate templates to reflect that schemes will have to provide slightly different information depending on whether they have reached the ‘relevant date’, or whether they are taking a fast track or bespoke approach.

In September 2024, TPR published its interim response on these plans along with a package of supporting documents, including revised templates and information to assist trustees with meeting their obligations.

In the final response to the consultation, the regulator set out the key themes identified in the responses to the consultation and how it ought to address concerns raised.

Additionally, the response also summarises the responses to the individual questions it asked in the consultation.

TPR’s plan to launch a 'submit a scheme valuation' digital service follows the regulator’s recognition that, as it requests more data, the method it establishes to collect it should be as efficient as possible, limiting the burden on trustees and aiming to meet the needs of those who will be using it while developing the new service.

In particular, TPR highlighted the diversity of DB schemes and has adopted a proportional approach, requesting less information from smaller schemes to reduce administrative burdens.

The Statement of Strategy emphasised the importance of long-term planning and risk management, encouraging trustees to set clear objectives and strategies for achieving low-dependency funding.

Barnett Waddingham principal, Mark Tinsley, said that TPR publishing its final response to the Statement of Strategy consultation and rolling out its new submit a scheme valuation service “marks a key development” in the new funding regime that all private sector DB schemes must navigate.

“The contents of the statement remain unchanged from TPR’s earlier interim response – meaning schemes still face an extensive information request to produce a document that is unlikely to prove useful as a risk management tool in practice,” he continued.

“Given that much of the Statement of Strategy structure is embedded in legislation, responsibility for this largely falls to the Department for Work and Pensions.

Tinsley pointed out that one “notable” advancement is TPR’s release of the “dynamic” spreadsheet that schemes will use to compile and submit their Statement of Strategy, highlighting that the format and functionality of this spreadsheet demonstrate “a real effort” by TPR to heed industry concerns.

“The new tool will allow for much-needed automation and simplification to the process, significantly reducing the workload compared to alternatives that would have required more manual intervention,” he added.

“Importantly, questions have been subdivided by speciality, enabling collaboration between advisers while avoiding unnecessary duplication. While completing the statement of strategy will still be a considerable task, this development represents a pragmatic step forward.”

Employer Covenant Practitioners Association (ECPA) vice chair, Helena Mules, said the ECPA “look forward” to TPR’s early feedback on these submissions, which it hopes will enable those yet to undertake their valuations to adopt these learnings and improve valuation outcomes.

Mules also noted that ECPA welcomes the ability to provide additional contextual information around trustees’ approach to covenant assessment, including the option to reference minimum funding figures to avoid “unnecessarily detailed analysis”.

However, Mules emphasised that trustees’ covenant assessments should continue to be guided by the Funding Code of Practice and Covenant Guidance, rather than being driven by disclosures within the Statement of Strategy itself.

“It remains clear that a well-considered and appropriately scoped covenant assessment is a critical element in facilitating the agreement of appropriate funding and investment strategies and ensuring better outcomes for members in the long term,” she added.

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