Raising The Bar For Pension Fund Benefit Administrators

Section 13B(1) of the Pension Funds Act, 1956 permits the Financial Sector Conduct Authority ("FSCA") to prescribe conditions for persons who administer the receipt of contributions or the disposition of benefits on behalf of retirement funds. Following at least four years of preparation, which included an opportunity for industry engagement, a number of significant conditions were prescribed by the publication of the FSCA Conduct Standard 2 of 2025 (RF) ("Conduct Standard 2") on 6 August 2025.

Conduct Standard 2 serves to enhance and bolster the existing regulatory framework applicable to administrators, as well as address existing shortcomings. Since 2002, conditions in respect of administrators have been prescribed by Board Notice 24 of 2002 ("BN 24"), which falls short of adequately addressing the significant policy and regulatory developments impacting the financial sector regulation, including the Treating Customers Fairly ("TCF") initiative, the 2014