The final provisions of the Financial Sector Conduct Authority’s Conduct Standard for pension fund benefit administrators take effect on 6 August 2026, bringing new requirements for administration agreements and outsourcing arrangements fully into force.
The date marks the end of the 12-month transitional period for paragraphs 11 to 14 of Conduct Standard 2 of 2025 (RF). It also coincides with the repeal of the remaining provisions of Board Notice 24 of 2002, completing the transition from the previous regulatory framework for benefit administrators.
When the Conduct Standard was published on 6 August 2025, the FSCA staggered its commencement dates to give benefit administrators and retirement funds time to review existing contractual arrangements, amend agreements where necessary, and implement new governance processes. Most provisions took effect immediately, while others commenced six months later. The requirements relating to administration agreements and outsourcing were deferred for 12 months.
Read: FSCA publishes final Conduct Standard for benefit administrators
The Conduct Standard forms part of the FSCA’s move towards a more outcomes-based regulatory framework for benefit administrators. It replaces a regulatory regime dating back to 2002 with more detailed requirements covering governance, customer outcomes, conflicts of interest, complaints management, administration agreements, and outsourcing.
Administration agreements
From 6 August, paragraphs 11 and 12 of the Conduct Standard, contained in Part VI, become effective. These provisions apply not only to administration agreements concluded after the Conduct Standard was published, but also to agreements already in force.
Paragraph 11 requires benefit administrators to have a written administration or service level agreement in place before providing services to a pension fund. The agreement must address a range of prescribed matters, including the services to be provided, the respective responsibilities of the parties, communication arrangements, remuneration, ownership of records, remedies for breach, the circumstances in which outsourcing is permitted, and procedures for terminating the agreement.
The Conduct Standard also prescribes that administration agreements must provide for a minimum notice period of 90 days before termination, unless otherwise approved by the FSCA.
New requirements when agreements end
Paragraph 12 introduces specific operational obligations when an administration agreement is terminated.
Benefit administrators must notify the FSCA within 30 days of the termination of an agreement. They must also transfer all relevant information, records, and documentation to the retirement fund or incoming administrator within 15 business days, ensuring that the transfer is complete and does not disrupt the administration of the fund.
Within 30 days after termination, administrators must also provide the fund with reconciliations of monies and assets under administration, together with reports on unresolved complaints and any outstanding administrative matters requiring attention.
Outsourcing arrangements
Paragraphs 13 and 14, contained in Part VII of the Conduct Standard, also come into operation on 6 August.
The Standard permits outsourcing only where this is provided for in the administration agreement and makes clear that outsourcing does not relieve a benefit administrator of responsibility for the functions performed on its behalf. Administrators remain accountable for outsourced services and for the records relating to those services.
Moonstone Compliance highlights paragraph 14. It requires benefit administrators to implement appropriate processes and procedures to manage, oversee, and regularly review outsourced services, and to conduct regular assessments to ensure ongoing compliance with the Conduct Standard’s outsourcing requirements.
The emphasis is therefore not simply on appointing service providers, but on maintaining effective governance and documented oversight throughout the life of an outsourcing arrangement.
Repeal of Board Notice 24
The commencement of paragraphs 11 to 14 coincides with a separate legal milestone.
Paragraph 41(2) of the Conduct Standard provides that the remaining operative provisions of the Conditions made in respect of Administrators acting on behalf of Pension Funds (Board Notice 24 of 2002) are repealed from 6 August 2026. Specifically, paragraphs 1 to 4 and paragraph 14 of the Board Notice fall away on that date.
The repeal means the Conduct Standard becomes the primary set of prescribed conduct conditions for pension fund benefit administrators under section 13B of the Pension Funds Act, replacing the remaining operative provisions of Board Notice 24.
From implementation to compliance
With the final transitional period coming to an end, the focus for benefit administrators shifts from implementation to demonstrable compliance.
From 6 August, administrators should be able to show that their administration agreements contain the prescribed terms, that termination procedures and record-transfer arrangements comply with the Conduct Standard’s requirements, and that outsourced services are subject to documented oversight, regular review, and ongoing compliance assessment.
For many administrators, this work will already have been completed during the past year. The commencement date nevertheless serves as an important reminder that the Conduct Standard’s requirements now apply in full to administration agreements and outsourcing arrangements, including those that pre-date its publication.
