FSCA Conduct Standard 2 of 2025 (RF)
Outsourcing checklist for benefit administrators
Use one checklist for each arrangement where your organisation delegates pension fund administration services to another benefit administrator. Covers paragraphs 13 and 14.
14 checks
Every requirement in paragraphs 13 and 14, with the evidence to look for.
In force 6 August 2026
Applies to existing arrangements too, including those entered into before publication.
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This checklist is an indicative self-assessment based on paragraphs 13 and 14 of FSCA Conduct Standard 2 of 2025 (RF). It does not constitute legal advice or a formal compliance opinion.
Paragraph 13(1): the fund administration agreement
Agreement with the fund
- 13(1)(a)
Does our agreement with the fund permit this outsourcing?
Evidence: Check the relevant clause in the signed fund administration agreement.
- 13(1)(b)
Does that agreement confirm we remain accountable for the duties, responsibilities and record keeping we outsource?
Evidence: Locate the clause that assigns continuing accountability to us.
Paragraph 13(2): before entering the arrangement
Fund consent and advice
- 13(2) Consent
Did each affected fund consent before we entered the arrangement?
Evidence: Compare the date of the fund decision with the date of the arrangement.
- 13(2) Advice
Before contracting, did we advise each fund of possible extra costs and any material changes that might occur later?
Evidence: Check the cost disclosure and the information sent to each fund.
Paragraph 13(3): customer outcomes and the provider
Being satisfied before outsourcing
- 13(3)(a)(i)
Are we satisfied that customers will be treated fairly and continue to receive satisfactory, uninterrupted service?
Evidence: Review the impact on members, including how payments will continue.
- 13(3)(a)(ii)
Will our organisation retain responsibility for key decisions?
Evidence: Check who has final authority for decisions and exceptions.
- 13(3)(b)(i)
Have we verified the provider’s FSCA approval as a benefit administrator under section 13B of the Pension Funds Act?
Evidence: Check its approval against the administration services being delegated.
- 13(3)(b)(ii)
Can the provider deliver the work reliably, effectively and professionally?
Evidence: Review staffing, expertise and capacity during peak processing periods.
- 13(3)(b)(iii)
Are we satisfied the provider can continue to meet this Conduct Standard?
Evidence: Review its compliance controls and how it deals with gaps.
Paragraph 13(4): contract terms
The written arrangement
- 13(4)(a)
Have we recorded the arrangement in writing and clearly covered every material aspect?
Evidence: Match the agreed terms to the services, responsibilities and risks identified.
- 13(4)(b)
Does it expressly give us access to the provider’s business and information relevant to the outsourced work?
Evidence: Locate the access clause and check what we can inspect or obtain.
Paragraph 14: once the provider is delivering the service
Ongoing oversight
- 14(1) Review
Do we use procedures to manage, oversee and regularly review how the provider carries out the work?
Evidence: Look at a recent review of benefit payment delays, errors or complaints.
- 14(1) Annual
Do we reassess all five paragraph 13(3) checks at least annually and record whether we remain satisfied?
Evidence: Compare the latest dated assessment with supporting evidence for each check.
- 14(2)
How do we identify shortcomings or breaches, and do we take appropriate action to address them?
Evidence: Trace one issue from detection through the action taken and its outcome.