Here is a summary of the scheduled discussions for the Pensions Committee meeting of the City of London Council on 22 September 2025. The meeting included discussion of the risk register, updates to the pension scheme administration, and the City Fund and Pension Fund statements. The committee was also scheduled to discuss guidance on transfers out of the pension scheme.

City Fund and Pension Fund - Statement of Accounts, Audit Findings and External Auditor's Annual Audit Report 2024-25

The committee was scheduled to consider the City Fund and Pension Fund Statement of Accounts, Audit Findings and External Auditor's Annual Audit Report 2024-25. The draft statement of accounts for the City Fund and Pension Fund had been presented to the Audit and Risk Management Committee on 14 July 2025. The report provided an update on the audit of the accounts, any changes and the auditor's findings. The audited 2024-25 City Fund Statement of Accounts were scheduled for approval. The set of accounts reflects the changes agreed with the auditors as part of their work. A copy of the draft Management Representation letter for the Pension Fund was scheduled to be presented. The Audit Findings Reports from Grant Thornton were scheduled to summarise the results of the audit and include the auditor's recommendation and details of any audit adjustments which have been made to the accounts. The external auditor's Annual Audit Report summarises all of the work that Grant Thornton had undertaken in relation to the City Fund during 2024-25. This includes their commentary on the City Fund's Value for Money (VfM) arrangements.

The committee was asked to consider the Audit Findings Report for the Pension Fund 2024-25, and the Pension Fund management representation letter 2024-25.

Risk Register

The committee was scheduled to review the Risk Register for the Pensions Committee. The report detailed the key risks that have been identified alongside a risk score which indicates the likelihood of a risk being realised together with the potential impact to the organisation and the appropriate mitigations. When reviewing the risks, the Pensions Committee were asked to be aware that some similar/generic risks are also included in the (CoL) Investment Committee Risk Registers: risks CHB Pensions 009 McCloud Remedy, CHB Pensions 007 Cyber security and 005 Fraud are on the CoL Police Pensions Board Risk Register and risk CHB Pensions 013 Responsible Investment Duties is on the Investment Committee Risk Register. The narrative risk update and latest note on associated actions has been amended where necessary. The Risk Register is included at Appendix 2 Risk Register. Members of the Committee were asked to review the risks and actions and confirm that appropriate measures are in place.

The committee was asked to:

• review the existing risks and actions present on the Pensions Committee's Risk Register, and confirm that appropriate control measures are in place; and
• confirm that there are no further risks relating to the services overseen by the Pensions Committee.

The risk register contained thirteen risks, including:

• McCloud Remedy
• Insufficient assets - Pensions Fund
• Cyber Security
• Targeted returns – Pension Fund
• Short term Cash flow
• Breach of GDPR/Data Protection regulations¹
• Employer Insolvency
• Pension Scheme Administration
• Service provider failure
• Governance/Legislative Compliance
• Failure to discharge responsible investment duties
• Fraud
• Actuarial Valuation

Pensions Administration - Guidance on Transfers Out

The committee was scheduled to approve the City of London Pension Fund Transfers-out document. In December 2024, the Pensions Committee received a report on Barnett Waddingham's General Code of Practice Compliance Review which checked the City of London Pension Fund's compliance with the Pension Regulators General Code of Practice. The Transfer-out Covering Report Sept 2025 followed up on the recommendation made at that Committee to produce a document that sets of the precautions take by the Pensions Administration team with regards to transfers-out of the pension scheme and avoiding potential scams. The City of London Pension Fund Transfers-out document sets out the processes and precautions taken by the Pensions Office when dealing with transfers-out of the pension scheme and the potential scams that could arise.

Pension Scheme - Administrator's Update

The committee was scheduled to note a report providing a summary of general information around a range of topics in relation to the administration of the Scheme since the last Committee meeting on 7 July 2025. The report included updates on:

• Annual schedule of events for the administration of the Pensions Scheme
• Information of Scheme Record Keeping
• Complaints or disputes under the Scheme's Internal Disputes Resolution Process (IDRP)
• Public Service Pensions - Reporting Breaches of Pension Law
• Any audit reports relating to the administration of the Scheme
• Any reports relating to the administration of the Pension Scheme which have been considered by other Committees
• Pension Administration System
• Transfers-of Pension Benefits
• Public Sector Pensions Legal Challenge - Lord Chancellor and Secretary of State for Justice v McCloud and others
• Pension Committee Training
• Pensions Office Key Performance Indicators
• Guaranteed Minimum Pension (GMP) Reconciliation
• Pensions Dashboards

Work Programme

The committee was scheduled to receive a report of the Chamberlain concerning the Work Programme. The Work Programme listed items scheduled for discussion in Q2 2025/26 (September), Q3 2025/26 (December) and Q4 2025/26 (February). Items included:

• Cashflow forecast
• Investment Strategy review
• Transferring assets to the LCIV² and Consultation Outcomes
• Mercer's review of inflation-linked benchmarks
• Risk Register
• Pension Fund Annual Report 2024/25
• City Fund and Pension Fund Accounts update 2024/25
• Draft Audit Findings 2024/25
• External Auditor Appointment
• Guidance on Transfers out
• Triennial Valuation Initial Results
• Draft Funding Strategy Statement and Employer Engagement Plan
• Principles of Responsible Investment
• TCFD³ report 2025
• Responsible Investment Policy Review
• Training Policy Review (inc. conflicts of interest)
• Draft Government Regulations and Guidance
• Pensions Portal training
• Cashflow forecast
• Triennial Valuation Final Results
• Funding Strategy Statement
• Refined Investment Strategy Review
• Risk Register
• Investment Consultant Strategic Objectives
• Updates to member communication letters (if required)
• Responsible investment/climate action (in house)