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Key definition
Winding up definition

What does Winding up mean? In pensions practice, winding up is the process of closing an occupational pension scheme, settling its liabilities and distributing its assets, after which the scheme trust is terminated and members’ benefits are secured elsewhere or paid out. It is a statutory concept used in the UK pensions regime (including the Pensions Act 1995 and the Occupational Pension Schemes (Winding Up etc.) Regulations 1996) and in Irish pensions legislation (the Pensions Act 1990). Key features include: identifying the winding-up trigger under the scheme rules or law (for example, employer insolvency or a trustee/employer decision), fixing the commencement date, notifying The Pensions Regulator...

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Winding up UK trust-based DC occupational pension schemes: classification, triggers, expenses, data cleansing, securing benefits, disclosures, trustee protections and completion

Practice notes
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This Practice Note sets out the principal steps for properly bringing to an end a Defined contribution (DC) occupational pension scheme—also described as a money purchase occupational pension arrangement or a trust-based defined contribution plan. Throughout this Practice Note, this type of arrangement is termed a ‘DC scheme’.

The guidance applies across a range of DC schemes, including trusts that sit outside the authorised master trust framework and small Self-administered pension schemes (SSASs), although the latter may, in certain cases, be excluded from particular statutory obligations or requirements.

This Practice Note does not cover the winding-up of any:

  • an ‘authorised master trust’ under the Pension Schemes Act 2017 (PSA 2017)—for further detailed information, please see Practice Note: The authorisation and supervisory regime for master trusts,
  • contract-based DC arrangements (eg group personal pension arrangements)—for further details and guidance, see Practice Note: Winding up of personal pension schemes

Statute makes distinct and specific provision for hybrid schemes (combining defined benefit (DB) and DC rights), and these should accordingly be treated as being beyond the ambit of this Practice Note, also together with DC schemes that were contracted-out using the reference scheme test (until 6 April 2016) and those with a...

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Leigh Holmes
Leigh Holmes

Leigh advises on a wide range of pensions issues. She has extensive experience of working with trustees and pension scheme employers through proposals to amend, close, wind-up and merge their schemes.Recent experience includes:Leading the advice team on a £90m buy-in (ready for conversion to buy-out) leading to the scheme's early exit from a Pension Protection Fund assessment period.Advising a group holding company in the context of a sale of an overseas division including negotiating guarantee terms with the trustees of two pension schemes to mitigate the impact of the sale and associated dividend payments.Advising in relation to allocation of assets on wind-up following exit from an assessment period and within a buy-in contract environment.Leigh is a director of Wrigleys Pensions Trustees Limited, a subsidiary company of the firm which is available to act as a corporate trustee to...

Louise Edwards
Louise Edwards chambers

Prior to qualifying as a solicitor, Louise worked in the pensions industry for a number of years in the areas of administration, consultancy and independent trusteeship. She now advises trustees and sponsoring employers of occupational pension schemes on all aspects of pensions law. She has particular experience in advising trustees regarding Pension Protection Fund entry (including the operation of the assessment period), buy-ins and buy-outs and the winding up of pension schemes. Louise is also involved in the day to day management of the trusteeships held by our pensions trustee company, Wrigleys Pensions Trustees Limited. Recent experience includes: Advising on buy-ins for schemes with insolvent employers but which were funded in excess of PPF compensation levels. Facilitating early exits from PPF assessment periods. A scheme transfer to the PPF following a successful reapplication process. Advising on the full buy out of scheme liabilities for schemes with solvent...

Web page updated on 22/05/2026

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