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New shareholder engagement requirements for trustees

Regulations were laid in Parliament on 6 June 2019 to improve transparency of information on how trustees engage with their asset managers.

The regulations will allow members and others to understand how funds are being managed and invested, further encouraging schemes to adopt a more long-term focus in their investment strategies. They also improve transparency of how schemes approach their engagement as shareholders.

These regulations also transpose Articles 3g and 3h from the EU Directive 2017/828 (more commonly known as Shareholder Rights Directive (SRD) II). This meets the UK’s obligation to transpose the EU Directive by 10 June 2019.

Schemes have some time to meet the requirements but should start the process now in order to meet the deadlines below.

The new requirements for pension schemes are:

  • defined contribution (DC) and defined benefit (DB) schemes must be transparent about their arrangements with their asset managers and include this in their Statement of Investment Principle (SIP) by 1 October 2020
  • DC and DB schemes must document their investment strategy and engagement policy with investee companies in their SIP by 1 October 2020
  • DB schemes must publish their SIP online by 1 October 2020;
  • By October 2021, DC and DB schemes must publish on-line how they have implemented their engagement policy, including voting behaviour by, or on behalf of, trustees (including the most significant votes cast by trustees or one their behalf) and state any use of the services of a proxy voter.

These changes build on the significant work the UK has already undertaken to improve the stewardship and governance of pension funds in the UK.

The regulations can be found on