This webpage sets out the (Regulatory) Board’s proposals and rationale for an updated APS X3 and associated guidance.
Deadline for responses: 31 August 2026
I invite you to participate in this consultation by the IFoA’s Regulatory Board (the Board) on proposals to:
APS X3 sets out the duties and responsibilities of members in providing expert advice during legal proceedings.
Following review of APS X3, the Board remains confident in the fundamentals of this high-level principles-based standard. Therefore, no changes to the standard are proposed beyond bringing some of the language up to date and making other minor amendments.
The Board welcomes comments from individual members, the organisations for which they work, other regulators and anyone else with an interest in the standards which the IFoA sets for its members.
We thank you for taking the time to consider these proposals and look forward to receiving your comments.
Sam Younger CBE
Regulatory Board Chair
APS X3 sets out the IFoA’s requirements for members acting as an expert in legal proceedings.
It applies to certain court proceedings in UK jurisdictions and requires members in other jurisdictions to consider the underlying principles of the standard and whether it would be appropriate to apply it. The standard also applies to settings other than courts, such as tribunals, arbitration, or mediation.
The standard builds on the principles outlined in the Actuaries’ Code.
This is a routine update. It is proposed that APS X3 is updated to be substantially consistent in format to other recently updated APSs, and that references to the IFoA Disciplinary Scheme are brought up to date. Some additional minor clarifications have been proposed, but no substantive changes to the underlying principles of APS X3 are proposed.
Download the tracked proposed revisions to APS X3 (version 2.1)
The Board is grateful for feedback provided by the IFoA’s Pensions on Divorce Working Party, which provided valuable insight for revising the guidance. Pensions on divorce cases make up a significant proportion of the work of members covered by APS X3.
In addition to clarifications based on scoping meetings held during review, case studies have been added to the guidance at various points, to help illustrate the ways members may want to approach applying APS X3 to their work. This, and a number of other steps have been taken to bring the guidance in line with the style and format of the IFoA’s most recent guidance releases.
Download the tracked proposed revisions to the guidance (version 2.0)
For the purpose of comparison, respondents may also wish to refer to the existing published guidance, which appears on the IFoA’s non‑mandatory guidance webpage.
The existing versions of APS X3 and its accompanying guidance contain out of date references and therefore need to be updated. The aim of the proposed changes is to ensure APS X3, and its accompanying guidance, remain up to date and reflect the needs of members.
The proposed changes are not expected to have any significant regulatory impact on members, in so far as they are limited to:
For the same reason, it is not expected that there will be any significant costs to members, or the organisations work which they work, in terms of training.
The proposed changes are considered by the IFoA’s Regulatory Board to be proportionate, consistent, transparent, and targeted, and have been developed in a way that is principles-based, and outcomes focussed.
IFoA standards and guidance are designed to help the IFoA meet its Royal Charter objective of protecting the public interest.
You can respond on behalf of an organisation or provide a personal response.
Download questionnaire for organisations (DOCX, 130 KB)
Go to the questionnaire for individuals
Or scan the QR code:
The deadline for responses is 31 August 2026.
Once the consultation has closed, the IFoA will reflect upon the feedback and publish more specific details of any changes. There will also be a period allowed before the changes come into effect so that those affected can take steps to ensure they are able to comply with the new requirements.