Completing Your Annual Compliance Statement
What is the ACS?
The Annual Compliance Statement (ACS) is a formal declaration by trustees confirming that their scheme complies with its obligations under the Pensions Act and IORP II Regulations. It is filed with the Pensions Authority once a year. The deadline is 31 January.Why it Matters
The ACS isn’t just a form — it’s a legal declaration. When you sign it, you are personally attesting that the scheme meets 20 specific governance, investment, and operational requirements. If any of those statements are false, you may be personally liable. This is why the platform requires you to review and confirm each question individually, with supporting evidence attached.Step-by-Step: Using the ACS Wizard
Open the ACS Wizard
Navigate to Compliance → Annual Compliance Statement in the platform. Click Start New ACS for the relevant scheme year.
Review the 20 compliance questions
The Wizard presents each question in plain language with:
- The relevant legal requirement
- Guidance on what compliance looks like
- A field to upload supporting evidence (optional but recommended)
Flag any non-compliance
If you cannot answer “Yes” to a question, mark it as Non-Compliant and add a remediation note. The platform will prompt you to set a remediation deadline.
Filing an ACS that accurately reflects non-compliance (with a remediation plan) is far better than filing a false declaration. The PA takes a proportionate approach to trustees who self-report and are actively remediating.
First trustee review and sign-off
Once all 20 questions are completed, the first trustee reviews the full statement and applies their electronic signature.
Second trustee sign-off
The ACS requires dual trustee sign-off. The platform automatically notifies the second trustee to review and sign. Both trustees must sign before the ACS can be submitted.
The 20 Compliance Questions
The ACS covers the following areas. Each question maps to a specific provision of the Pensions Act or IORP II Regulations:| # | Area | What you’re confirming |
|---|---|---|
| 1 | Trustee appointment | Trustees are properly appointed and registered |
| 2 | Fit & proper | Trustees meet fit & proper requirements |
| 3 | Trustee training | Trustees have completed required training |
| 4 | Key Function Holders | KFHs are appointed and notified to the PA |
| 5 | KFH fit & proper | KFHs meet fit & proper requirements |
| 6 | Own-Risk Assessment | ORA is in place and up to date |
| 7 | Written policies | All 11 mandatory policies are adopted and reviewed |
| 8 | Investment policy | Investment Policy Statement is in place |
| 9 | Remuneration policy | Remuneration policy is in place |
| 10 | DORA / ICT risk | ICT risk management policy is in place |
| 11 | Outsourcing | Outsourcing arrangements are documented and compliant |
| 12 | Conflicts of interest | Conflicts policy is in place and applied |
| 13 | Member communications | Members receive required information |
| 14 | Benefit statements | Annual benefit statements issued on time |
| 15 | Funding | Scheme is funded in accordance with requirements |
| 16 | Actuarial review | Actuarial review is current |
| 17 | Audited accounts | Accounts are audited and filed |
| 18 | Data protection | GDPR compliance in place |
| 19 | Scheme wind-up provisions | Wind-up rules are documented |
| 20 | Regulatory reporting | All required reports filed on time |
Dual Trustee Sign-Off
The ACS must be signed by at least two trustees. The platform enforces this:- Trustee 1 completes the review and applies their signature
- The platform notifies Trustee 2 by email
- Trustee 2 reviews the completed statement and applies their signature
- Only then can the ACS be submitted