TPR Places Trusteeship And Value At The Centre Of New Strategic Plan

Raising the bar for trusteeship

TPR plans to launch a formal trusteeship strategy to set clearer expectations and raise standards across the pensions sector. The strategy will highlight the qualities and behaviours TPR expects from trustee boards, including being focused on member outcomes, capable of constructive challenge, data-driven, professionally skilled and accountable for decisions.

The plan makes clear that schemes must be well governed, underpinned by reliable data and open to innovation. Where trustees are unable to meet these expectations, TPR encourages consolidation with larger or better-governed schemes.

TPR’s supervisory model will be expanded to cover a broader range of schemes and trustee types. Master trusts, public service pension schemes, administrators and professional trustee firms will come under closer scrutiny, with greater use of regulatory tools where governance or administration standards fall short.

Preparing for the Pension Schemes Bill

The upcoming Pension Schemes Bill is expected to introduce significant changes across both defined contribution (DC) and defined benefit (DB) markets. TPR’s plan sets out how it will support the industry in adapting to new requirements, including those relating to retirement products, governance and investment strategy.

Among the most notable changes is the proposed duty for trustees to ensure schemes offer appropriate decumulation options. This would mark a shift away from viewing workplace pensions as savings vehicles alone, towards supporting members through to, and beyond, retirement.

Trustees are also expected to review how they manage funding surpluses in DB schemes. TPR will look for evidence of clear policies and decision frameworks, particularly where schemes are significantly overfunded. The absence of a distribution strategy may be treated as a governance concern.

Emphasis on value for money

The corporate plan includes a strong focus on value for money. TPR will work with the Department for Work and Pensions (DWP) and the Financial Conduct Authority (FCA) to deliver a cross-regulator framework that holds schemes to account for the quality of outcomes they deliver.

Trustees will be expected to disclose clear metrics across cost, performance and service quality. The regulator will challenge schemes that do not provide evidence of good value, or that are unable to demonstrate how their approach benefits members over the long term.

This aligns with a wider shift in regulatory emphasis from inputs and intentions to real-world outcomes. TPR will aim to be more targeted and risk-based in its supervisory activities, with clearer expectations, greater transparency and stronger enforcement where standards are not met.

Supporting innovation and data-led decision making

TPR continues to encourage trustees to embrace digital solutions and emerging technologies. The regulator sees opportunities for schemes to improve governance, administration and member experience by making better use of data and analytics.

Trustees will be expected to adopt open-data principles, improve reporting transparency and support regulatory engagement through digital channels. TPR will also review how it collects and uses scheme data to reduce duplication and improve reporting processes.

Innovation will also play a role in how schemes respond to changing saver needs. The regulator is developing a supportive framework for the trialling of new retirement solutions, including those that use artificial intelligence or alternative engagement tools. Trustees are expected to explore such options where they could enhance member outcomes.

Responding to structural change and new delivery models

As consolidation continues, trustees are being asked to assess new governance and delivery models. These include fiduciary management, run-on strategies, master trusts, superfunds and insurance vehicles.

TPR expects trustees to take professional advice and carry out detailed risk assessments before moving into new arrangements. While innovation and restructuring may offer benefits, the regulator warns that careful oversight is essential to ensure members remain protected and outcomes are not compromised.

A more assertive regulatory stance

The plan suggests TPR will take a more assertive approach to enforcement where necessary. A new enforcement strategy for trustees will be introduced, with targeted interventions where governance, compliance or member outcomes are judged to be at risk. Trustees across all scheme types are expected to take a proactive approach to meeting these higher expectations. TPR will continue to use outreach, guidance and supervision, but has made clear it will act quickly and decisively where failings occur.

As the regulatory environment becomes more complex, the role of trustees is expanding. TPR’s latest plan underlines the need for stronger skills, deeper engagement and a clearer focus on delivering outcomes that reflect members’ long-term interests.

Luke Carter, Regulatory Consultant at Equiniti said, “TPR’s new corporate plan shows that expectations of trusteeship standards are evolving. The focus on outcomes, digital capability and value is welcome, but schemes will need to think carefully about how they evidence performance. Trustees who embrace data and good governance will be well placed for what lies ahead. Careful consideration and preferably clear guidance on what constitutes value will be needed for such a subjective topic.”