Minimal changes expected to AS TM1; final UK Stewardship Code guidance shared

The Financial Reporting Council (FRC) has launched a consultation on the Actuarial Standard Technical Memorandum 1 (AS TM1), confirming that no significant amendments are expected. 

The FRC's annual review of AS TM1 considered changes in market volatility and return expectations over the year, and found that the accumulation rate assumptions and volatility boundaries in AS TM1 remain appropriate. 

However, whilst FRC has proposed no changes to the assumptions, it has proposed a minor wording amendment relating to fund volatility calculation dates to clarify its policy intention.

Stakeholders have until 1 December 2025 to provide feedback on the consultation, with results of the consultation set to be published by 15 February 2026.

FRC executive director of regulatory standards, Mark Babington, said: “It is vital that pension scheme members can trust the consistency and reliability of their pension illustrations.

"The government’s continued commitment to pensions dashboards reinforces this priority, and we’re pleased that AS TM1 underpins this work as key tool to help users understand their pensions.”

In separate news, the FRC has also published its guidance to support the updated UK Stewardship Code 2026, which was shared in June alongside draft guidance to support applicants’ reporting. 

The FRC explained that, as a result of a wide range of stakeholder feedback to the call for comments, it has now made amendments and finalised the guidance. 

These changes were welcomed by the UK Sustainable Investment and Finance Association (UKSIF), which had previously expressed its disappointment that the new code definition excludes direct references to ‘environment’ and ‘society’.

UKSIF head of policy and regulatory affairs, Oscar Warwick Thompson, said: “We welcome the FRC’s finalised UK Stewardship Code guidance, which will offer principles-based support to firms in reporting against the new code’s framework.

“It’s encouraging to see direct references to systemic risks maintained within the guidance – including opportunities for signatories to show how they identify and respond to these risks – backed up by examples of how this can be done in practice.

“The guidance also appears to usefully differentiate between alternative forms that investor engagement can take. Separately, it’s positive that the new industry-led voting template developed by the Vote Reporting Group, now under the ownership of Pensions UK, is cited as an example for standardised vote reporting.

“We hope to see the finalised guidance help reinforce expectations under the revised code on the importance of a high-quality standard for investor stewardship practice and stewardship reporting.”

The guidance, which is optional, offers suggestions for the types of information organisations may wish to include in their reporting to help explain their approach to stewardship.

The guidance is designed to reflect the flexible nature of the code, recognising that organisations differ in size, structure, and investment strategy, and therefore exercise stewardship in different ways.

The FRC said that it will also continue to engage with signatories to support their transition to reporting against the updated code.



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