Skip to main content

​
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.
Missing the ACS deadline is a direct breach of the Pensions Act. The PA monitors filings and will follow up with schemes that do not file on time.

​
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

1

Open the ACS Wizard

Navigate to Compliance → Annual Compliance Statement in the platform. Click Start New ACS for the relevant scheme year.
2

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)
Work through each question. You can save your progress and return at any time before submitting.
3

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.
4

First trustee review and sign-off

Once all 20 questions are completed, the first trustee reviews the full statement and applies their electronic signature.
5

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.
6

Submit to the Pensions Authority

Once both trustees have signed, click Submit ACS. The platform submits the statement and generates a timestamped submission receipt, which is stored in the scheme’s compliance record.

​
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:

​
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
Don’t leave the second sign-off until the last moment. Build in at least a week before the 31 January deadline to allow both trustees to review and sign.

​
What to Do If You Miss the Deadline

If you miss 31 January, file as soon as possible and contact the Pensions Authority proactively. The platform records the submission timestamp, so late filings are clearly visible. A late but complete and accurate ACS is better than no ACS.