Information on key function holder appointments

27 September 2022: Today, the Pensions Authority publishes information for trustees on the appointment of a service provider to carry out more than one key function.

In accordance with the Authority’s Code of Practice for trustees, when trustees enter into an outsourcing contract with a service provider, a named individual must be specified as responsible for delivery of the relevant key function.

Trustees may appoint the same service provider to deliver both the internal audit and risk management key functions for a scheme as long as the named individuals responsible for the delivery of the services within that entity are different and have distinct roles and resources. The different key functions must be operated independently with appropriate safeguards to ensure conflicts of interest are avoided. In particular, the trustees should be satisfied that the service provider has implemented the necessary practices and procedures to ensure independence of the internal audit function within its overall operations.  

Trustees are reminded that they must notify the Authority of any arrangement concerning the outsourcing of a key function not later than four weeks following the making of that arrangement but in any event before the agreement in respect of that arrangement enters into force. Guidance on how to notify the Authority of key function holder appointments is available on the Authority’s website.


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For further information, contact:

Technical Unit
The Pensions Authority
Tel: (01) 613 1900