The guidance originally confirmed that trustees could agree to a reduction or suspension of deficit repair contributions (DRCs) where it was necessary to support an employer during the pandemic, subject to certain restrictions. The guidance confirmed that the Regulator would take no action regarding failure to pay DRCs for the three months from 20 March 2020. The Regulator acknowledges that this facility will still be needed by many schemes. However, the revised guidance confirms that although such concessions may still be granted, the Regulator expects that most trustees should now be able to undertake more accurate and detailed due diligence on the employer's financial position before agreeing a new suspension or reduction.

The guidance states that the Regulator understands that only a small proportion of employers have asked to suspend or reduce contributions and that it believes that around 10% of schemes have agreed a temporary suspension or reduction of DRCs so far.

The Regulator confirms that it is aware of a limited suspension of transfers by schemes. The suspension of the concession that allowed trustees to not report any delays in the transfer value process, and not risk regulatory action, will be lifted and the Regulator requires trustees to resume the reporting of breaches in transfer obligations from 1 July 2020. It also requires that trustees continue to provide its standard letter to members looking to leave their DB scheme, see Legal update, COVID-19: Pensions Regulator issues guidance on member communications in response to emerging risks.

The Regulator considers that there should now be sufficient financial information available to allow trustees to more accurately review the employer covenant, as funders may now be seeking increased protection from employers. Trustees should assess whether any adverse effects of the pandemic on the employer's covenant are likely to be short-term (particularly as regards affordability) or more permanent. Decisions on risk should then be reconsidered based on this knowledge. The revised guidance includes questions for trustees to help assess the covenant impact of COVID-19.

The majority of the reporting easements that were granted to schemes will end on 30 June 2020. As well as in respect of the suspension or reduction of DRCs, and any delays in transfer values, trustees should also continue to report on any delays to finalising a scheme's scheme valuations and any revisions to the recovery plan, with a suitable explanation for the actions taken by the trustees.

The Regulator will continue to allow DC and automatic enrolment providers 150 days to report late payments of contributions. Previously, it had required information on late payments within 90 days. This will be reviewed at the end of September 2020, as the Regulator considers that the results of the 150-day reporting period will not be seen until that time.

The Regulator states that it will continue to take a "pragmatic approach" to delays in the issue of annual benefits statements. It accepts that the impact of COVID-19 means that schemes need additional time to issue these to members.

From 30 June 2020, master trusts should return to issuing a formal report to notify the Regulator of all triggering and significant events.

The Coronavirus Job Retention Scheme will close on 31 October 2020. The Automatic enrolment and DC pension contributions: COVID-19 guidance for employers document has been amended to reflect that, from 1 July 2020, staff on the scheme may return to part-time work for their employer. It has also been updated in respect of the withdrawal of the facility for employers to claim a grant for up to the statutory minimum automatic enrolment employer contribution from 1 August 2020, see Practice note: COVID-19: issues for pension schemes: Reduction in CJRS compensation from August 2020.