Sackers responds to the DWP’s consultation on trustees and governance

Building on its 2023 consultation on Pension trustee skills, capability and culture, back in December 2025 the DWP published a new consultation addressing “Trustees and governance, building a stronger future”. With the consultation closing tomorrow, Kirsty Pake, partner, comments:

“Whilst light on specific proposals at this stage, the consultation nonetheless covers a lot of ground, including the composition and skills of trustee boards, as well as how occupational pension schemes are governed and administered more broadly. Occupational pension schemes are highly regulated, with powers and obligations derived from a wide range of sources. Given the sheer volume of legal and regulatory requirements, the trustee role is an increasingly complex and substantial undertaking.”

“Trustees are subject to common duties, but the spectrum of trustee models and governance structures in place is vast and diverse. We are fortunate to work with the full range of trustee arrangements and see the breadth and diversity of the industry as a source of strength.”

“Rather than imposing additional prescriptive standards on trustees, in our view the better way forward would be to continue to support and empower trustees to reflect on their effectiveness. After all, this principle of self-reflection is already a key component of the “Own Risk Assessment”, which many trustees are currently undertaking for the first time.”

“While training and accreditation can help to evidence technical competence, effective trusteeship relies heavily on intangible soft skills that are not so easily measured, including judgement, communication and an understanding of member needs. In our experience, it is the unique blend of backgrounds, experience, life skills and attributes which each trustee brings that ultimately influences effectiveness. An over-emphasis on testing formal knowledge risks overlooking the importance of these wider competencies.”

“Having perhaps once been seen as largely a back-office function, administration is now rightly viewed as critical to good member outcomes. As a firm, we work with a full range of third-party and in-house administration models across the industry. We are strong advocates of the importance of administration to a well-governed scheme, and very much welcome the continued focus on risks and opportunities in scheme administration.”

“The challenge for trustees is how to understand, oversee, and maximise their strategic partnership with their scheme’s administrators. This requires an ongoing dialogue based on collaboration, openness, and an appreciation of one another’s perspective. We would be supportive of a fuller consultation on administration, building on key themes identified in recent regulatory and industry guidance. This could draw out those key themes in more detail seeking input from the providers operating in this space as to how inherent risks are be managed and could be further mitigated.”

“We were delighted to participate in the focus group who prepared new guidance from the Pensions Administration Standards Association, with part one of the series on trustee and administrator engagement published this week. We welcome the continued focus and recognition of the central role that administration plays in delivering good member outcomes.”

Read our full consultation response.