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TUPE and Pensions

The TUPE laws only apply to employers who provide employees with membership of occupational pension schemes (i.e. Defined Benefit or Occupational Money Purchase schemes).

If an employee is transferred under the TUPE regulations and they were a member (or they were eligible to become a member) of their former employer's occupational pension scheme, then their new employer must provide them with access to one of the following:

  • A Defined Benefit scheme (e.g. final salary) which satisfies the standard required to contract out of the State Second Pension; or
  • A scheme which provides benefits based on an employer contribution of at least 6% plus any member contributions; or
  • A money purchase scheme (including stakeholder schemes) in which the employer agrees to match the contribution made by the employee up to at least 6% of their basic pay

The new employer must make a pension scheme available from the date of the TUPE transfer (or the end of the waiting period, if applicable).

The employee and their new employer can agree to opt out of these obligations and agree alternative arrangements at any time after the transfer of employment takes place.

The TUPE rules on pension rights do not apply to members of non-occupational pension schemes, such as Group Personal Pensions and Stakeholder Pensions.

However, if the previous employer had a contractual obligation to pay a certain level of contribution into a non-occupational pension plan, then that obligation transfers to the new employer along with other contractual terms and conditions.