PASA published industry guidance on artificial intelligence (AI) late last year. In this blog, we share our views on that guidance and what it means for trustees.

“Be curious, with caution”

The PASA guidance closes with the tagline “be curious, with caution” – a message we strongly support.

AI offers the pensions industry huge opportunities for greater efficiency and enhancing member experience. Many of our trustee clients are keenly engaged with how their providers are adopting this new technology.

At the same time, AI brings a range of legal and governance risks which trustees need to understand, monitor and manage.

Curiosity – how can AI be harnessed by schemes?

The PASA guidance gives great examples of how AI can be used to improve efficiencies in pension administration. It encourages organisations to embrace the possibilities of AI and contribute to a more innovative pensions ecosystem.

Caution – responsible guardrails

The guidance places a strong emphasis on data, reminding trustees to “keep data at the top of [their] priority list”. This is a timely reminder: AI systems are only as reliable as the data they are trained and operated on. Poor quality data can affect the accuracy, usefulness and trustworthiness of any AI driven output.

PASA rightly acknowledges that the risks of AI are significant. These include data breaches, embedded bias, and opaque or untrustee-like decision-making. The guidance makes clear that AI tools should never be used to replace human decision-making.

Best practice in 2026

For trustee boards looking to demonstrate “AI best practice” in 2026, curiosity needs to be accompanied by clear, documented guardrails. From our perspective as legal advisers, that means taking practical steps like:

  • engaging with current service providers to understand whether, where and how AI is used (or is planned to be used)
  • arranging trustee training on AI
  • adopting a trustee AI policy setting out key principles, expectations and accountability
  • identifying and assessing AI risks within the scheme’s risk register
  • ensuring contractual AI safeguards and data protection controls are in place with service providers.

Please contact your usual Sackers contact if you’d like to know more.