Revised Code of Transparency now published

In July 2025, the Board reported that it would be holding a consultation on proposed changes to Code of Transparency following on from the decision to replace the centralised data system supporting the Code with a framework approach. The consultation was open from 14 July 2025 to 15 August 2025.  36 responses were received from fund and pools (as clients) and Code signatories (including pools). 100% of the Code signatories that responded indicated that they would remain committed to the Code. The final draft was put to the Investment Committee on 10 November and was approved for publication on 24 November 2025 by the Board. The Board is hopeful that these changes to the Code alongside the new framework expected to go live in 2026 will ensure that the Code continues to deliver on its intended aims of increased transparency within the sector. A summary of the key changes can be found below. The revised Code can be found on the Code of Transparency section of the website along with updated FAQs to reflect these changes.

The key changes made to the Code post consultation are as follows:

1. The definition of pools has been changed to align with the definition contained in the Pension Schemes Bill and the definitions of investment managers has been edited to account for the role of pools in appointing external managers in addition to in-house investing activities. There is also included a definition for the financial year.
2. The introduction section now accounts for the distinction between administering authorities in Scotland and Northern Ireland who will continue to handle day to day investment activities and pools in England and Wales who will be fully taking on this function on behalf of their participating administering authorities from 1 April 2026.
3. Paragraph 5 includes reference to the Freedom of Information Scotland Act (FoISA) in addition to the originally included Freedom of Information Act (FoIA) and the respective Codes of Practice made under them. It also includes the Pools as an entity subject to these regulations in light of their changing role.
4. In Paragraph 8, the deadline for the time that an investment manager has to develop the infrastructure necessary to provide its clients with investment cost data has decreased from twelve to six months. This reflects feedback and suggested timescales from existing Code signatories who indicated that while a reduction from twelve months in the previous version of the Code was possible, moving to the three months proposed in the initial consultation would have been too steep and would not be achievable in cases where new signatories have a significant number of LGPS clients or amount of LGPS assets under management (AUM).   
5. Paragraph 12 lays out the timescales for the submission of templates, with a reduction of the 90-day deadline detailed in the Code FAQs to 60 days in the case of public market templates. The deadline for private market templates will remain as 90 days. The Code FAQs which have also been updated, lays out the option of submission of private markets data on a calendar year basis, which may assist in providing data to clients in time for the production of fund annual accounts (accounts need to be issued by 31 May).
6. Reference to the ‘Administering Authority and/or Pool’ contained in the Code for consultation have now been changed to ‘Administering Authority or Pool’ in the finalised version to clarify the aforementioned distinction between the operating model in England and Wales from Scotland and Northern Ireland. These references can be found at paragraphs 
7. Paragraph 14 makes clear that ‘Administering Authorities and/or Pools should make arrangements to ensure that they have a means of collecting and validating data from the templates’. This has been added to make clear to all parties that this cost data should be actively sought and utilised, and Code signatories should expect to be held to account by their clients if the data is not provided as required. The Board intends to reinforce this messaging by recommending to the Ministry of Housing, Communities and Local Government that they include references to the Code in revised statutory guidance to the 2016 LGPS Investment Regulations that will be issued to implement the Fit for the Future proposals, and the updated Annual Report Guidance published in April 2024 (see Paragraph 32 on pg. 11 of the document).
8. Paragraph 22 further clarifies the instances in which the Board would revoke the status of a Code signatory.