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Publication duties
UK trustees of schemes with 100 or more members must put the SIP on a public website, free of charge. No login, no registration, no personal details. Search engines must be able to index the page. The implementation statement and the chair's statement extracts go alongside. The underlying documents must be prepared within seven months of the scheme year end.
A reference note from Dan Malone, who builds software products.
The rule
“Whether produced as one document or separated out, the information required to be made publicly available under regulation 29A and 29B of the Disclosure Regulations must be published on a publicly available website.”
The facts
| Field | Value |
|---|---|
| Who must act | Schemes with 100 or more members must prepare a statement of investment principles. The governing body must publish it online, free of charge. Source |
| Legal basis for the website duty | Regulation 29A(1) of the Disclosure Regulations 2013 says the specified information must be made publicly available on a website. It must be free of charge. Source |
| SIP review cycle | Trustees must review the SIP at least every three years, and without delay after any significant change in investment policy. Source |
| Chair's statement deadline | Trustees or managers of a relevant scheme must prepare the annual governance statement. This must happen within seven months of the end of each scheme year. Source |
| Annual report deadline | The annual report carries the implementation statement. It must be prepared within seven months of the end of each scheme year. Source |
| No gate on the page | Readers must not have to enter a user name or password. They must not have to give any other personal information about themselves. Source |
| Search engines must reach it | The guidance says the page should not include text that prevents indexing. It should link to other pages that search engines find. On a third-party site, the public and indexable options should be selected. Regulation 29A(3)(b) requires trustees to have regard to this guidance. Source |
| One page is not required | The information can sit across several linked web pages or PDF files. Schemes do not have to publish a signed version; the signature can be removed first. Source |
| Hard copy fallback | A person can ask for hard copy. Trustees must send it within two months, if website access would be unreasonable for that person. Source |
| The address goes in the benefit statement | The specific web address must appear in the member annual benefit statement. It should be titled so members can re-type it into a browser. Source |
| Penalties on failure | A first failure to prepare the chair's statement carries a mandatory penalty. The range is GBP 500 to GBP 2,000. Source |
| Real compliance rate | TPR reported that 220 defined contribution schemes should have given a web address for the SIP and implementation statement. Only 180 did. Most of the other 40 addresses were missing or did not work. Source |
The artefact
What goes wrong
/01
The annual report sign-off slips past the seven-month date, so the public page still shows last year's documents.
/02
The documents sit behind the member login or a portal that asks for a scheme number. The guidance rules this out.
/03
A noindex tag, or a page with no inbound links, keeps search engines off the disclosure page.
/04
The web address given in the benefit statement or the scheme return is dead after a site rebuild.
/05
The SIP passes its three-year review, the trustees agree a new version, and nobody swaps the published file.
Who supplies this
Large UK professional trustee and scheme secretarial firm. Scheme secretaries usually own the disclosure calendar and the published documents.
https://vidett.com/our-services/
Pensions consultancy with a dedicated scheme secretarial team that prepares chair's statements, SIPs and implementation statements for trustee boards.
https://www.barnett-waddingham.co.uk/services/
Actuarial and investment consultancy. Advises on SIP content and runs digital member communication services where scheme documents are hosted.
https://www.hymans.co.uk/services/
Trade body. Publishes implementation statement guidance for trustees of DB, DC and hybrid schemes, plus vote reporting templates. The templates download from the member area.
https://www.pensionsuk.org.uk/Policy-and-Research/Document-library/Implementation-Statement-guidance-for-trustees
Runs public trustee disclosure pages for scheme clients. The linked page shows the pattern: a plain public URL holding the SIP and implementation statement.
https://epa.towerswatson.com/accounts/huk/public/honeywell-uk-pension-scheme-statement-investment-principles/
Send the duty, the deadline and where it has to sit. What comes back is a written scope for the page, or a straight answer that you do not need one.
Send the briefLast checked 2026-09-01 · Published 2026-09-01
This page is reference material, not legal advice. Your advisor owns what applies to you.