Jurisdiction(s):
United Kingdom

Related legal acts

Key definition

Governance definition

What does Governance mean? Governance, in pensions practice, describes how a trustee board organises itself and exercises oversight, decision-making and control over an occupational pension scheme to meet legal and fiduciary duties. It encompasses the scheme’s structures, policies and internal controls, and how trustees delegate to and supervise advisers, administrators and asset managers, monitor performance, manage risk and record decisions. The term is descriptive rather than a defined legal term, but key governance requirements are prescribed in legislation and regulatory codes. In the UK, the Pensions Act 2004 and scheme administration/governance regulations, together with The Pensions Regulator’s General Code, require an effective system...

FCA COBS 19.5: Independent Governance Committees and GAAs for workplace personal pensions and investment pathways—composition, duties (ESG and value for money), annual reporting and publication

Published by a LexisNexis Pensions expert

Practice notes

This Practice Note centres on the FCA requirement at COBS 19.5 for workplace personal pension schemes to set up an independent governance committee (IGC). For wider detail on the governance duties that apply to workplace personal pension schemes, see Practice Note: Governance requirements applicable to DC workplace pension schemes—Governance requirements for workplace personal pension schemes.

What is an IGC?

Since 6 April 2015, certain FCA‑authorised pension providers must have a governing body called an IGC, although in some limited scenarios a governance advisory arrangement (GAA) may take its place. For more on GAAs, see Alternative arrangements to IGCs—governance advisory arrangements (GAAs), below.

IGCs act independently of the provider and are intended to perform a function akin to trustees of occupational pension schemes. An IGC is established to represent the interests of the following groups so that their investments benefit from an impartial review by the IGC:

since 6 April 2015, active and deferred members of relevant personal pension schemes, and
since 6 April 2020, customers who have invested in ‘pathway investments’.

The term ‘pathway investment’ is a concept that applies in...

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Web page updated on 21/05/2026

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