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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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UK personal pension scheme wind-ups: planning, FCA Consumer Duty, stakeholder triggers, member communications, transfers, discharges and HMRC reporting

Practice notes
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This Practice Note explores the legal and practical considerations that arise when a personal pension scheme is wound up by its provider, the scheme administrator, and any trustee.

What does it mean?

Care must be taken to distinguish the winding up of a personal pension scheme from an employer’s choice to stop participating in the arrangement which, in the context of employee relations, may be portrayed as the winding up or closure of the employer’s group personal pension plan.

Any pension arrangement that is not an occupational pension scheme is a personal pension scheme, and it must, in general, be created by a person with permission under the Financial Services and Markets Act 2000 (FSMA) to establish a personal pension scheme or stakeholder pension scheme in the UK.

Unlike occupational pension schemes, a personal pension scheme does not have to be set up under irrevocable trusts.

The term personal pension scheme is defined in the Financial Services and Markets Act 2000 (Regulated Activities) Order 2001, SI 2001/544 as any scheme, other than an occupational pension scheme or a stakeholder pension scheme, intended to provide benefits for individuals:

  • on retirement
  • on reaching...
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Alistair Hill
Alistair Hill chambers

Alistair is a Legal Director in the Brodies pensions team, where he practices both as an English and as a Scottish solicitor.  He helps a broad range of employers, trustees and other professionals with defined benefit and defined contribution pension schemes, including advising on the pensions aspects of corporate transactions and public/private sector staff transfers. From his days in-house at a leading insurer, Alistair has also retained an active interest in developing and maintaining defined contribution pension propositions from the provider's and administrator's viewpoint, such as personal pension, mastertrust and SIPP products.  While he would argue passionately that clients shouldn't haven't to worry about them unless they want to, Alistair has always been interested in the more technical aspects of pensions law.   Besides his work for LexisPSL, this has led him to play an active role in the professional bodies and more generally in debating law reform and...

Web page updated on 22/05/2026

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