ORA: Proportionate Governance for Confident Compliance

Client context

IGG provided secretarial and governance services to a medium-sized UK pension scheme with just under 2,000 members. Prior to IGG’s appointment, the Trustee had already undertaken a detailed review of its Effective System of Governance (ESOG) and maintained a structured policy review programme as part of the scheme’s wider business plan.

The Trustee had taken considered, proportionate decisions on where documentation was required and where it was not considered relevant to the scheme’s risk profile. Governance documentation was therefore already well developed, albeit not designed with the Own Risk Assessment (ORA) in mind.

The challenge

Following the introduction of The Pensions Regulator’s General Code of Practice, the Trustee was required to complete its first ORA. The challenge was not a lack of governance, but ensuring that existing arrangements could be:

• reviewed objectively against the General Code
• evidenced appropriately within the ORA framework
• confirmed as proportionate and defensible

The Trustee wanted to avoid unnecessary duplication, retain confidence in prior governance decisions, and complete the ORA within regulatory timescales without creating additional burden.

Solution

A proportionate ORA approach grounded in existing governance

IGG approached the ORA by building directly on the scheme’s existing ESOG framework rather than re-documenting governance from scratch.

An ESOG gap analysis was completed using IGG’s standard governance framework, focusing on alignment with the General Code. This confirmed that the majority of policies and controls were already in place, with only limited areas requiring further confirmation or clarification.

IGG then completed the ORA using its adaptable ORA template, identifying:

• areas where Trustee risk appetite or approach needed to be reconfirmed
• instances where additional assurance from third-party providers would strengthen Trustee confidence
• documentation gaps that warranted reconsideration in line with good practice

At the request of the Trustee sub-committee overseeing ESOG and ORA, IGG provided regular written progress updates. These highlighted completed sections, emerging themes and proposed actions, ensuring transparency throughout the process and avoiding late-stage surprises.

Result

Early sign-off, clear actions and Trustee confidence

The ORA report was reviewed by the sub-committee and, following minor refinements, presented to the full Trustee Board one quarter ahead of the regulatory deadline.

The report confirmed that the scheme’s governance framework was robust and proportionate. The resulting action plan was focused and realistic, with most actions already in progress as part of existing business plans. Examples included:

• scheduled cyber-related training
• routine policy reviews already planned for the following quarter

The Trustee Board signed off the ORA more than three months ahead of the deadline. Feedback highlighted:

• confidence in the robustness of the approach
• clarity on where action was, and was not, required

assurance that prior governance decisions remained appropriate and defensible

Why this matters

For schemes with established governance frameworks, ORA delivery is less about volume of documentation and more about judgement, assurance and proportionality.

This case demonstrates that ORA can:

• build effectively on existing ESOG work
• reinforce confidence in governance decisions already taken
• provide structured assurance without unnecessary complexity

Our role

IGG supports trustees by applying structured governance frameworks in a proportionate way. Our role is to ensure regulatory requirements are met while respecting scheme-specific context and prior Trustee decisions.

The value

For this scheme, IGG’s approach enabled:

• a focused and proportionate ORA process
• early identification and confirmation of key risks and controls
• timely Trustee engagement without deadline pressure
• confident sign off well in advance of regulatory requirements

This approach ensures governance supports effective decision-making as well as regulatory compliance.

Key Contact