Getting ready for… your Own Risk Assessments (ORA)

The General Code has now been in place for over a year and schemes must ensure they are compliant with its requirements. A key element of this framework is the ORA (Own Risk Assessment), a structured evaluation of how effectively a scheme identifies, manages, and mitigates risks. The ORA must be completed for all pension schemes with over 100 members, within 12 months of the end of the first scheme year that starts after the Code came into force on 28 March 2024. For example, for a scheme with a 31 March 2024 year end, the deadline would be 31 March 2026. In this example, the first scheme year after the General Code took effect is 1 April 2024 to 31 March 2025, and 12 months from the end of this scheme year is 31 March 2026.

With the ORA (Own Risk Assessment) deadline starting to kick in next year, here at Pi Partnership, whether as trustee or as pension manager, we are acting now to ensure our client’s schemes are prepared. This includes ensuring:

  • A clear governance framework. With outlined roles and responsibilities of trustees, employers, and third-party providers. A documented governing body policy that sets out how governance is monitored and improved, and a risk register that is regularly updated and reflects current scheme risks.
ways to get ready for your ORA (Own Risk Assessments)
  • Identifiable risk management processes. A documented risk management policy that details how risks are identified, assessed, monitored, and mitigated. Clear escalation and reporting procedures for emerging risks. Evidence of regular risk discussions in trustee meeting minutes.
  • Internal controls and compliance measures. A structured internal control framework that ensures operational effectiveness. Policies for data protection, cyber security, and business continuity. Monitoring and reporting mechanisms to confirm ongoing compliance.
  • Trustee training and knowledge management. Evidence that trustees have completed required training on governance and risk management. A knowledge and understanding policy to ensure trustees remain up to date with regulatory developments.

To support and evidence ORA (Own Risk Assessment) submissions, we are ensuring that schemes can present clear documentation demonstrating compliance with the General Code. This includes trustee meeting minutes, an up-to-date risk register, records of trustee training on governance, cyber security, and regulatory compliance, internal and external audit reports reviewing governance effectiveness and service provider contracts outlining key responsibilities and risk management practices.

There are a number of steps that we are undertaking to prepare for our ORAs here at Pi Partnership. We have already reviewed existing governance arrangements against the General Code requirements. We are now engaged in updating and enhancing risk management frameworks, ensuring all risks are documented and assigned mitigation strategies.

How Pi Partnership Are Preparing For Own Risk Assessments (ORAs)

Our next steps will be to:

  • Gather supporting evidence to demonstrate compliance and effectiveness.
  • Conduct an internal assessment or engage an external consultant to review governance structures and processes.
  • Document findings in an ORA (Own Risk Assessment) report, outlining areas of strength, improvement actions, and ongoing monitoring plans.
  • Ensure trustees and key stakeholders review and approve the ORA before submission.

For trustees and pension managers working through the process, there is some excellent support and guidance from several sources, including TPR’s website, the Pensions and Lifetime Savings Association (PLSA), the Pensions Management Institute (PMI) and professional advisers. We would be happy to discuss or provide additional support for any schemes with limited resources.

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Amanda Burden

Director and Governance Specialist

Amanda is a Board Director of Pi Partnership Group and leads the development of Pi’s services. She works closely with clients, the Pi team and professional advisers to ensure all of Pi’s services meet the changing needs of the pension market and deliver clear value to Pi’s clients.

Amanda has over twenty-five years’ experience in the pensions industry and, as well as ensuring Pi’s services continue to meet the needs of our clients in a rapidly changing pension landscape, is also a member of Pi’s Executive Management Team. She provides specialist project management for clients on a range of services, including adviser selection and review, trustee board assessment and governance design.

As well as being a Fellow of the Pensions Management Institute (PMI) and Chair of the PMI London Group, Amanda holds PMI certificates in Pensions Automatic Enrolment and DC Governance, was a past Prince2 practitioner and is a Certified Risk Management Practitioner.

What do you most enjoy about your role:  Successfully delivering complex projects and creating a happy team environment.

Interests outside work: Travel, theatre and as part of Abundance London helping create beautiful spaces in urban settings.

Top achievement to date: Competing in the 2005/06 Round the World Clipper race.