Compliance with General Code Regulations
Improved Governance and Effective Decision-making
Enhanced Risk
Management
Establish and Maintain an Effective System of Governance
The Pensions Regulator’s (TPR) new General Code, published on 28 March 2024, consolidates and refines previous codes of practice to set clearer, higher standards for UK pension scheme governance and member protection. (The five codes of practice that have not been incorporated in the General Code are expected to be incorporated at a future date.)
For trustees, this means new pressure: out-of-date policies, weak controls, or a “tick box” approach now put your scheme and your members at risk. The Regulator expects clear evidence of robust, effective governance at every level.
Part of the Code’s requirements for those running UK occupational pension schemes is to establish and maintain an Effective System of Governance, or ESOG. This means having strong policies, practical processes, and effective controls in place - and being able to prove it. The Code sets out nine key areas where trustees must be able to demonstrate effective governance:
Nine Key Areas Of An Effective System Of Governance
To comply with the new Code, every scheme must have clear, robust policies and procedures covering these nine essential areas:
For schemes with over 100 members, you’ll need to go further - demonstrating not only that these nine areas are covered, but also how well they work in practice.
This is where the Own Risk Assessment (ORA) comes in: a regular (at least triennial) review and documented assessment of how your ESOG is actually operating. Unlike some scheme documents, the ORA does not need to be routinely filed with TPR, but you must be able to produce it on request.
Our Credentials
Assure UK is a specialist pensions audit and assurance firm. We are trusted by some of the UK’s largest pension schemes to deliver high quality, insightful and effective audit and assurance services.
We have supported Trustees through the implementation and appraisal of an effective system of governance and have experience in advising Trustees on effective Integrated Risk Management (IRM) solutions for pension schemes.
Why Choose Assure UK for ESOG and ORA
Our effective and timely communication, excellent project management, and high-quality execution give you peace of mind.
We work to fixed fees and complete transparency to ensure value for money for you and your members.
Proportionality is imperative for Trustees when designing their ESOG and responding to the requirements of the General Code.
We work with a very varied portfolio of UK occupational pension schemes, from small, non-complex entities to some of the largest UK master trusts, multi-employer and single trust DC, DB, and hybrid schemes.
We can flex our approach to support these differing needs and ensure a cost-effective, tailored service.
How We Can Support You With ESOG And ORA
Worried about meeting the Pensions Regulator’s new governance requirements? Not sure if your scheme is ready for an Own Risk Assessment (ORA)?
At Assure UK, we offer practical, hands-on support at every step of your ESOG and ORA journey:
Book a free initial consultation to find out exactly how we can help your scheme.
Policies and Documentation: How Far Are You From Implementing An ESOG?
How does your current system of governance compare with the requirements of the general code?
Gap Analysis and System Planning: We can assist you in identifying gaps in scheme policies and documentation that prevent you from establishing an Effective System of Governance.
We can review and appraise your current structure making pragmatic recommendations for you to consider and implement.
Review your policies against our list of required policies and procedures.
Processes and Procedures: How Far Are You From Implementing An ESOG?
How does your current system of governance compare with the requirements of the general code?
Gap Analysis and Action Planning: We can assist you in identifying gaps in scheme processes, controls, and Trustee monitoring activities that prevent you from establishing an Effective System of Governance. We can review and appraise your current structure, making pragmatic recommendations for you to consider and implement.
Tailored Review of Governance Processes covering the effectiveness of monitoring the key nine areas of the General Code.
Assurance Mapping, Risk Register Review
Trustee Board Effectiveness Review
Internal Audit Review, Assurance Deep Dives
Own Risk Assessment: Does your ORA reflect your ESOG and demonstrate the actions the Trustee board undertake to manage scheme risks effectively?
Preparing your ORA can feel like a significant challenge - especially when you want to demonstrate real, effective governance and meet the Regulator’s expectations.
We guide you step-by-step through the process, using our proven ORA template and hands-on support:
- We’ll review your ESOG and draft ORA, providing practical, independent feedback to help you strengthen your assessment.
- Our assurance-led approach highlights enhancements and improvements, so you can be confident your ORA is robust, credible, and ready for scrutiny.
Ready to take the pressure off with expert support? Get in touch with our ESOG and ORA specialists - Laura Casserly, Bhavesh Patel, Jade Brooker, Olivia Bailey, and Luke Bosch - for an initial discussion.
Helpful, adaptable, reliable and easy to work with
Assure UK were very responsive and gave clear explanations to their reasoning throughout the process.
It is a great team with highly professional members and plenty of experience. Commendable style of dealing with clients and very courteous
Your 3-Step Path to ESOG & ORA Confidence
Want to Check Your Scheme’s Readiness? Download Our Free ESOG & ORA Checklist
Get instant clarity on your scheme’s compliance.
Our step-by-step checklist helps trustees identify strengths, spot gaps, and prepare for the new regulatory expectations - covering all nine key areas of an Effective System of Governance (ESOG) and readiness for your Own Risk Assessment (ORA).
What you’ll get:
- A simple, practical checklist - ideal for both lay and professional trustees
- A quick way to benchmark your governance, policies, and processes
- Immediate guidance on where to focus next
Download your free checklist now - just enter your email to get started.
We’ll send your checklist straight to your inbox. You’ll also be invited to book a complimentary review session with one of our specialists, should you want personalised feedback on your results.