Making changes to the Registered Pension Schemes Manual (RPSM)

HM Revenue & Customs (HMRC) working with industry and representative bodies

Pension Schemes Services is opening a new revision process for updating the RPSM manual in conjunction with industry.

A virtual room will be opened on the HMRC website, specifically to share drafts of significant guidance changes to the Registered Pension Schemes Manual (RPSM). This RPSM room is designed to allow both authors within HMRC and experts outside HMRC, to work collaboratively on early drafts, through to a near final text.

The room is a part of a broader Shared Workspace (SW) facility, which in this case will allow structured collaboration over a period of broadly eight weeks for any particular batch of legally significant changes. It is hoped that content from the first batch of changes to RPSM (relating to FB/FA 2008) should begin to be available in the RPSM room around the 5 March 2008. Dates of later batches will be announced to members of the RPSM room using the SW facility. Organisations wishing to become involved in this process, whether now or at a later stage, need to take a number of preliminary steps.

  • Everyone that will be involved needs to become familiar with the different gate-keeper and contributor roles (outlined below) that are part of the working methods of SW.
  • Every organisation will also need to initially identify three people to fill specific roles before their members/employees/customers will be able to gain access to the guidance drafts.

Roles

The primary role is that of a Customer Organisation Representative (COR), typically a senior responsible manager role, who will in turn appoint two Customer Nominated Contacts (CNCs). Customer in this context refers to customers of HMRC. The CNCs will then operate through the new online system, to introduce content contributors from their organisation to SW. These content-contributors are called Customer Members (CMs) of the room. These roles are necessary even if there is to be only one CM for an entire organisation, although of course the CNCs may allow a larger number. Both the CNCs and all the content contributors will need to go through a registration and enrolment process before they can use SW. It is also highly recommended that they complete some free online learning in advance of registration. Likewise all CMs are encouraged to complete the learning.

Joining the RPSM room

The CNC registration process typically takes around two weeks, as it involves both surface mail and electronic registration. Once an organisation has two CNCs in place, registering individual contributors as CMs of the room is much quicker. Once CMs are registered, they should be able to continue to collaborate on future changes without further administration.

Organisations wishing to collaborate on RPSM guidance changes should contact PSS via email to

Jon Burnell and provide the following information:

  • the name of the COR
  • how they would like the organisation identified on the system (eg company or representative body name)
  • the organisation's head office postcode
  • the COR's email address, to which HMRC will send the COR's electronic invitation to SW

Please ensure you head your message with SW RPSM room.

Scope

Initially PSS expects around 20 organisations to join up, although if things progress well this number can increase. It is also presumed that an organisation will only want a modest number of expert members to contribute content changes. These observations are made as we are unsure about the impact on HMRC authors and CMs themselves if there were a very large number of contributors. PSS will therefore keep such matters under review.

Confidentiality

Because the RPSM room is designed to facilitate collaboration between HMRC and multiple customers, participants will need to accept that their contributions will be open to all members of the room, including possibly business competitors, to view and comment upon. There can therefore be no presumption of confidentiality regarding the guidance production drafts.

HMRC will use the RPSM room for developments in legislation that have been announced. This may include pre-draft legislation stages. Naturally where work is done on the strength of outline proposals much may change as the legislation progresses. However, there may also be instances where the opposite is true. Namely that some work has to be done before a proposal can be announced at all. This might occur for example, for more serious compliance reasons. In any such latter case, PSS will aim to introduce the work into the RPSM room as soon as the developments have been announced.

Background

This initiative follows the Review of Links with Business, as was first touched on in Newsletter 32.