Occupational pension scheme wind-up checklist (DB and DC): TPR-guided steps on data cleansing, s75 employer debt, GMP equalisation, securing benefits, trustee discharge, statutory disclosures and final regulatory notifications

Published by a LexisNexis Pensions expert

Checklists

THIS CHECKLIST APPLIES TO OCCUPATIONAL PENSION SCHEMES

This checklist highlights the key actions involved in bringing an occupational pension scheme to a close—whether a defined benefit (DB) or defined contribution (DC) arrangement—and aligns with winding-up guidance from the Pensions Regulator (TPR). For fuller detail on these steps, see Practice Notes: Winding up a defined benefit (DB) occupational pension scheme; Winding up a defined contribution (DC) occupational pension scheme; and Winding-up an occupational pension scheme—statutory disclosure from 6 April 2014, reporting and record-keeping requirements.

Data cleansing and reconciling records

Once trustees decide to wind up the scheme, they should carry out a thorough data cleansing exercise. As this can be lengthy, it should, where practicable, be completed before formal winding-up starts. Where trustees cannot control the timing of the wind-up, cleansing and planning should begin as early as possible within the winding-up process.

As part of the data cleansing exercise, trustees should:

Check and reconcile member records. Where the scheme is a former contracted-out DB scheme, this includes verifying GMP records with HMRC...

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Web page updated on 20/05/2026

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