Identify the “beneficial owners” of the pension plan – “beneficial owner” captures:

• all trustees
• the original sponsoring employer
• the current plan employers
• all identifiable pension plan beneficiaries (such as active members, deferred members, persons in receipt of pension and pension credit members)
• any categories of undetermined beneficiaries
• all other individuals who could be said to exercise “control” over the plan. This could capture, for example, the directors of a corporate trustee or a plan actuary whose consent is required to any form of plan amendment.

Collate information required to be kept in respect of “beneficial owners” who are individuals. This includes:

• full name
• national insurance number or unique taxpayer reference
• if the individual does not have a national insurance number or unique taxpayer reference, the individual’s usual residential address. If the address is outside of the UK, passport number or identification card number or equivalent form of identification
• date of birth, and
• nature of role in relation to the pension plan. 

Collate information required to be kept in respect of “beneficial owners” who are corporate bodies, this includes:

• corporate/firm name;
• unique taxpayer reference;
• registered principal office;
• legal form of the legal entity and the law by which it is governed;
• if applicable, the name of the register of companies in which the legal entity is entered including details of the EEA State or third country in which it is registered;
• registration number; and
• nature of the entity’s role in relation to the plan.