Sackers responds to TPR consultation on extending the CDC code of practice

TPR has proposed updates to its CDC code so that it will cover both single-employer CDC schemes and the new unconnected multi-employer CDC schemes from 31 July 2026. We welcome TPR’s approach to creating a single, comprehensive CDC code as this will make it easier to follow and apply in practice.

The expansion of CDC is a central part of the ongoing policy changes designed to improve retirement outcomes for members of DC schemes. In our consultation response, we emphasise the importance of recognising trustees’ overarching trust law duties because the nature of CDC schemes is likely to involve CDC trustees weighing up different stakeholder interests over time. We suggest making these duties more explicit within the code to support trustees in their decision-making. This is crucial given the potential for complex questions around fairness and intergenerational matters in CDC schemes. To strengthen the code’s usability, we encourage TPR to clarify the responsibilities of different parties involved in multi-employer CDC schemes, especially regarding the preparation and approval of business plans, and promotion and marketing obligations.

As master trusts look to be the most likely vehicle for the first wave of multi-employer CDC sections, it is important to consider how the master trust and CDC authorisation and supervision regimes will function together. We believe more guidance would be beneficial to help schemes manage these “mixed benefit” arrangements.

With further changes likely on the horizon to accommodate retirement-only CDC schemes, it is reassuring that TPR plans to evolve its approach to keep pace with the changing market.

Read our full consultation response.