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Disclosure of senior managers’ remuneration (Greenbury) 2021

We anticipate that the Greenbury functionality within Pensions Online (POL) will be available from Monday 4 January 2021 (provisional, to be confirmed in December’s newsletter). Requests for disclosure information should be received by NHS Pensions between 4 January 2021 and Friday 26 February 2021 to enable us to provide you with the necessary disclosure information to meet your reporting timescales.

1. Who should employers request Greenbury figures for?

The Department of Health and Social Care Group Accounting Manual (GAM) 2020-21 states the remuneration report must disclose information on those persons in senior positions having authority or responsibility for directing or controlling major activities within the group body. This means those who influence the decisions of the entity as a whole rather than the decisions of individual directorates or departments.

The GAM goes on to say:

“The Chief Executive or Accounting/Accountable Officer must be asked to confirm whether this covers more than the executive and non-executive directors (for CCGs – attendees at Governing Body meetings). It is usually considered that the regular attendees of the entity’s board meetings are its senior managers.”

The NHS Foundation Trust Annual Reporting Manual (ARM), defines senior managers as follows:

The definition of senior managers is ‘those persons in senior positions having authority or responsibility for directing or controlling the major activities of the NHS foundation trust’. The chief executive should confirm whether this covers more than the chair, the executive and non-executive directors of the NHS foundation trust (who should be treated as senior managers as a matter of course).

2. What will NHS Pensions provide?

NHS Pensions will provide disclosure information for executive directors and other senior managers, as confirmed by the chief executive. We will not carry out any calculations for non-executive directors because they do not meet the criteria in the GAM of a senior manager, due to their self-employed or fee-based status.

3. What if an executive director is also a medical General Practitioner (GP)?

Disclosure information will only be provided where the GP is an employed senior manager or executive director. If the GP is employed (i.e. contract of service) by a Clinical Commissioning Group (CCG) as a senior manager or executive director and pays pension contributions then they will be classed as an officer for pension purposes and Greenbury disclosure will apply.

If the GP is also engaged under a contract for services arrangement (i.e. self-employed) by a CCG then Greenbury disclosure will not apply to this element of their work. Under this arrangement, the GP is afforded practitioner status which is not included in the calculation of the accrued pension, lump sum and cash equivalent transfer value (CETV).

Where NHS Pensions is asked for disclosure information for a GP and their pension record holds practitioner membership only then we will assume they are a non-executive director and no information will be provided. It is important for employers to check that the pension records of their senior managers are completely updated.

NHS Pensions will provide information based on calculations using NHS staff (officer) membership only.

This exercise only relates to remuneration in public bodies which means GP practices and most direction bodies are not required to take part.

4. How to submit disclosure information requests for the 2021 exercise

• Employers must request Greenbury senior manager remuneration disclosures for the 2010/21 financial year via Pensions Online (POL).
• These screens will also be used by NHS Pensions to return the requested pension, lump sum (where applicable) and CETV to each employer.
• Employers will only be able to view their own disclosure requests.

The Pensions Online Guidance for Greenbury is available on our website at

Employers will need to nominate a user and allocate Greenbury access to that user before disclosures can be requested. Employers will be able to use the previous year’s user and password details. If you have any queries about registering a user on POL, please contact the POL Helpline on 0870 011 7108. Any other Greenbury queries should be directed to

The Greenbury screens will also support:
• communication between employers and NHS Pensions concerning Greenbury queries
• requests for re-calculation of Greenbury disclosures
• comparison of this year’s disclosure figures with last year’s figures

Full guidance on how to register and use the POL system to make your requests is now available on the Pensions section of our website