Not only is an employer required to send the right paperwork out to the right person at the right time, they have got to record they have done so and keep that record. Each assessment of staff needs to be recorded, in case the Regulator wishes to review this.

The employer must also register with the Pensions Regulator within 5 months of their Staging Date and continue to do so every 3 years. If they are using an old pension scheme and Certification, this needs to be updated every 18 months to ensure they are still meeting their legal obligations.

Basically it is up to the employer to be able to prove they have adhered to their legal duties.

Governance reverts back to the continuing review of the performance and suitability of the default fund.