1 February 2012 is the cut off time by which trustees, who were trustees prior to and after 1 February 2010, must have completed their trustee training. Trustees appointed since 1 February 2010 had to receive training within six months of their appointment. 

Every trustee of an occupational pension scheme (except a death benefit only scheme) must undertake trustee training in accordance with the Pensions Act. If you are an employer who operates a scheme you must arrange for the trustees of that scheme (other than a professional trustee or a pensioneer trustee) to receive appropriate training. A failure to do so could result in fines and even imprisonment. 

In light of the above, it would be prudent for both employers and trustees to ensure that they have met their obligations and, in particular, that trustees, who were trustees on 1 February 2010, have undertaken relevant training prior to the 1 February 2012 deadline.  An alternative course of action could be to replace the current trustees with a professional trustee (who the employer is not required to arrange training for) before 1 February 2012.