Preparing for Own Risk Assessment

If you’re a trustee of an occupational pension scheme with 100 or more members, your first Own Risk Assessment (ORA) deadline is approaching. As part of The Pensions Regulator’s (TPR) new General Code—effective from 28 March 2024—you’ll be required to complete and document an ORA within 12 months of your next scheme year-end. For most schemes, that means Spring 2026.

But what exactly is the ORA, and how can you prepare effectively?

What is an Own Risk Assessment (ORA)?

The ORA is a holistic governance review that evaluates how well your scheme’s Effective System of Governance (ESOG) is working in practice. It’s designed to help trustees assess the actual application of their policies, identify risks, and ensure regulatory compliance—not just on paper, but in real day-to-day scheme management.

When is the ORA Due?

Your scheme’s first ORA must be completed within 12 months of the end of the first scheme year after the General Code came into effect. In most cases, this means a deadline of Spring 2026—but that doesn’t mean you should wait to get started.

Why Does the ORA Matter?

Beyond regulatory compliance, the ORA gives you the chance to:

• Reflect on how your scheme operates
• Review whether governance policies are being followed
• Strengthen risk management processes
• Deliver better outcomes for members

Good governance isn’t just a box-ticking exercise—it leads to better decisions and long-term scheme resilience.

Key Governance Questions to Consider

As we and the pensions industry as a whole, readies itself in preparation for the ORA, detailed work needs to be done on the “so what” questions:

• We have got the policy, but are we checking that we are actually doing what it says?
• What’s the point of the policy?
• Is it working,
• Are we adhering to it?
• One size generally doesn’t fit all, so what is important in order to adapt the process to meet your scheme requirements?

These questions are all pre-cursers to the ORA in terms of assessing the effectiveness and usefulness of the current documented policies.

Planning for the ORA: What, When, Why

To aid trustees thinking on the strategy phase, IGG has provided clients with training to aid understanding of the “What, When, and Why” aspects of the ORA.

We help trustees build a tailored, practical ORA approach using a simple framework:

🔍 What?

Define the scope:

• What needs to be reviewed?
• Who will carry it out?
• Who is responsible for the Risk Management Function?

🕒 When?

Work backwards from the deadline. As well as sufficient time to undertake the assessment, you should also:

• Allow time to discuss the findings as a Trustee Board
• Schedule actions based on findings
• Ensure the Chair’s Declaration is prepared and signed

🎯 Why?

The ORA is your opportunity to step back and ensure your scheme is governed effectively. Amidst the operational workload, it provides a structured moment to focus on governance quality and outcomes.

We all know that governing bodies are busier than ever, and it can be difficult to make time for governance activities amongst all the other business of managing a scheme, however the foundations of good governance must be central to scheme management. We know that in the long term, good governance supports better decision-making and will lead to better outcomes for members, so it is important to give it sufficient focus.

Making Policies Work in Practice

It’s important to recognise that putting policies in place is not a ‘one-off/job done’ effort – it is crucial to test that those policies work, not just on paper but also in practice. Do they need to be adapted to meet those requirements – and are they actually being used?

Often, there is a danger that policies are put in place and then not reviewed or renewed regularly. Over time, key contacts will likely change, as will systems, processes or documentation – so, after a while, they may not remain fit for purpose.

Policies must evolve alongside your scheme. There should be rigour around regular reviews to ensure they remain up to date and fit for purpose. Key evaluation questions include:

• Is the policy aligned with current legislation?
• Does it reflect our current operations and risks?
• Is it written clearly enough for new trustees to use?
• Is it helping or hindering efficiency?

Regular review is essential to avoid outdated or irrelevant policies that expose your scheme to unnecessary risk.

Don’t Forget Your Advisers

It’s not just about the policy, in undertaking the Own Risk Assessment, Trustees must also assess the governance and risk management practices of third-party advisers and service providers.

Your ORA should evidence their compliance with the General Code—another reason to maintain strong relationships, clear communication, and documented expectations.

Practical Steps for a Smooth ORA

Maintain good filing systems and audit trails. Once gaps are addressed, keeping comprehensive records and evidence of progress is so important. This not only supports ongoing governance reviews but also ensures that Schemes are well-prepared for the ORA and any future regulatory requirements.

Here’s how to stay ahead:
✅ Keep well-organised records and audit trails
✅ Build governance reviews into your annual cycle
✅ Assign ORA responsibilities clearly
✅ Review all key policies and risk assessments
✅ Document all discussions and decisions

Being proactive and structured now will reduce stress later and put you in a strong position ahead of regulatory scrutiny.

How IGG Can Support You

At IGG, we take a pragmatic and proportionate approach to the ORA. We help trustees and in-house pension managers manage compliance without adding unnecessary complexity. Our services include:

• ORA awareness and training sessions
• Policy and governance documentation reviews
• Full ORA execution and support
• Strategic guidance aligned to your scheme’s size and risk profile

Find out more about our ORA services here.

Need Help with Your Own Risk Assessment?

IGG recognises the juggle for in-house Pensions Managers in terms of additional governance requirements vs extremely busy day jobs!  Whether you need training, support, or a full delivery partner for your ORA, IGG is here to help. We work with schemes of all sizes to ensure compliance, improve governance, and reduce the burden on your internal team.

👉 Get in touch today to discuss how we can support your scheme.

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