Northern Ireland Widens CMP Rules for More Employers

If you opened this Northern Ireland statutory rule and felt lost by line three, that is a fair reaction. The document is long, technical and packed with cross-references. But the main change is quite clear: from 31 July 2026, Northern Ireland allows a wider kind of collective money purchase pension scheme to sit inside the law. The Regulations were made by the Department for Communities on 30 July 2026 and came into operation the next day. In plain English, they extend the collective money purchase framework so it can cover schemes used by multiple employers that are not all connected to one another. That is the big shift everything else in the document is trying to control.

**Quick guide:** a collective money purchase, or CMP, scheme is a pension where contributions are pooled and invested together. Members do not get a guaranteed final pension in the way they would in a classic defined benefit scheme, and they do not simply hold a fully separate individual pot either. Instead, the scheme aims to provide benefits using shared assets and actuarial calculations. That matters because the income members receive can move up or down over time. The Regulations repeatedly stress that benefits are not guaranteed, investment performance can change, and even the rate or amount of benefits can fluctuate. So when you read 'collective money purchase', it helps to translate it as pooled pension money with shared rules and no promise of a fixed outcome.

Until now, the law mainly worked for a single employer or for employers connected with each other, such as companies in the same group. The new rules write two categories into the Pension Schemes Act 2021: a 'single or connected employer scheme' and an 'unconnected multiple employer scheme'. The second category is the new one readers should watch. It means a scheme can be used by two or more employers where some or all of them are not connected. That may sound like a dry legal tweak, but it opens the door to multi-employer CMP models that could serve unrelated businesses rather than one corporate family. The older 2024 Northern Ireland regulations still cover single or connected employer schemes; these 2026 rules build the matching system for unconnected ones.

But opening the door wider also raises a more obvious question: who is really in charge, and who carries the cost if something goes wrong? The Department for Communities answers that by building a tighter authorisation regime around these unconnected schemes. According to the statutory rule published on legislation.gov.uk, an unconnected multiple employer scheme must have a single 'scheme proprietor'. That proprietor is the person or entity expected to make the commercial decisions and to stand behind the scheme financially, including set-up costs, authorisation costs, running costs where charges are not enough, and costs that arise if a triggering event hits. In other words, the law is trying to stop responsibility being blurred across lots of employers.

That is why the Regulations spend so much time on accounts, business plans and financial sustainability. An unconnected scheme must submit a business plan, the latest scheme accounts if any exist, the proprietor's accounts, and in some cases the accounts of bodies funding the proprietor. The Pensions Regulator must also be satisfied that the scheme's business strategy is sound, not just that there is money available today. **What this means for readers:** this is less about paperwork for its own sake and more about proof. The business plan must cover at least three years and no more than five, be reviewed at least once a year, and be revised when there is a significant change. The application fee is usually £77,000, which shows this is not a light-touch process.

One of the most striking parts of the new rules is how much attention they give to promotion and marketing. For unconnected schemes, the Pensions Regulator must be satisfied that no one has marketed the scheme in a way that is unclear or misleading without putting that right quickly. If nobody is marketing the scheme, that must be stated too. The law also says promotion should explain plainly that investment returns can fluctuate, the expected value of benefits is not guaranteed, benefits themselves can rise or fall, and members need clear information about what happens if the scheme cannot continue. Trustees are kept at arm's length from selling the scheme: they must not promote or market it, and they must not act as its chief or senior financial officer. That separation is there to reduce conflicts of interest.

The checks do not stop with trustees. The fit and proper test can also reach the scheme proprietor, people involved in marketing, senior finance officers and senior investment officers. The Regulations set out the sort of background information that can matter, including regulatory breaches, insolvency history, criminal convictions that are not spent, disqualification as a director and serious civil judgments. There is also a time limit on schemes that win approval but never really begin. If the Pensions Regulator authorises an unconnected scheme and nobody has started operating it within 24 months of the application, the authorisation must be withdrawn, unless the regulator grants an extension of up to six weeks for good reason. The message is simple: authorisation is not meant to be a badge kept on a shelf.

The back end of the Regulations is all about what happens when a scheme is under strain. New triggering events are added for situations involving the scheme proprietor, including insolvency or a decision by the proprietor to end its relationship with the scheme. The Act's continuity options are the routes a scheme can take after a serious problem: option 1 is winding up and discharging liabilities, option 2 is resolving the triggering event, and option 3 is converting the scheme into a closed scheme. That matters because the new authorisation tests do not just look at how a scheme starts. They also ask whether trustees would be free to choose option 3 if it becomes the right answer, unless the law forces option 1. The rules also require actuarial valuations within the first year of operation and then at least every year after that, alongside reporting duties, implementation strategies and close contact with the Pensions Regulator if trouble appears.

So why do these Northern Ireland changes matter beyond pension specialists? Because they may help create a bigger market for collective pension schemes, especially for employers that are too small or too separate to run one on their own. That could mean more experimentation in how workplace pensions are organised, though not an instant change to anyone's payslip or retirement date. The safest reading is this: the law is saying yes, but carefully. Yes, unconnected employers can now be brought into the CMP model. But only if the scheme has one accountable proprietor, stronger evidence of financial backing, honest marketing, regular actuarial checks and a clear plan for trouble. For readers trying to make sense of the document, that is the thread that holds the whole thing together.