Background

On 15 December 2025, the DWP published a consultation on trustees and governance in trust-based pension schemes. This consultation builds on the 2023 call for evidence, to which we also responded.

In this response

General comments

We welcome the opportunity to respond to this consultation. In addition to answering selected questions which are pertinent to our practice, or which we believe could give rise to difficulties in practice for our clients, we have provided some general comments.

Diversity of schemes, trusteeship and governance arrangements

The range of occupational pension schemes and types of trusteeship varies widely. For example, sitting alongside the more conventional DB, DC and hybrid occupational pension models, there are now DC master trusts and DB superfunds, not to mention the anticipated emergence of Collective DC and eventually DC “Megafunds”. Furthermore, some schemes are supported by professional trustees, while others follow a more traditional lay trustee board composition. Even among schemes that have appointed professional trustees, there is variation in how professional trustee firms operate and the services offered, with each having its own governance template. These differences naturally have a bearing on how governance arrangements function in practice.

A scheme’s size, complexity and status, as well as the stage of its evolution, will likewise impact its overall governance and the relationships between the parties involved. For example, for occupational pension schemes that remain open to new members and/or future accrual, ongoing relationships between the sponsoring employer(s), trustees and members will play a crucial role, with member representation and engagement a vital element. In contrast, such roles will naturally need to adapt where a closed scheme is heading towards buy-out or winding-up. Similarly, the parties involved in larger, consolidation pensions vehicles, where employer involvement is more dialled down, will be very different again.

Against this backdrop, it seems to us that any new obligations around trusteeship and governance would require careful navigation. The existing legal and regulatory framework balances flexibility and prescription well and we would encourage this position to be maintained.. Where possible, sufficient flexibility should be baked into any new obligations so as to accommodate the degree of diversity resulting from differing schemes, trusteeship and governance arrangements. This would reduce the risk of unintended consequences arising from the application of uniform expectations.

Knowledge, skills and effective trusteeship

Occupational pension schemes are highly regulated, with trustee powers and obligations derived from trust law, scheme rules, case law, both pensions specific and relevant non-pensions legislation, as well as regulatory requirements. Given the sheer volume of legal and regulatory requirements, the role of an occupational pension scheme trustee is a highly significant undertaking.

While training and accreditation can help to evidence technical competence, effective trusteeship also relies heavily on skills that are not easily measured or accredited, including judgement, independence of thought, leadership, communication and an understanding of member and employer contexts. These intangible “soft skills”, particularly important for chairs, are often developed through experience rather than study. Other work or general life experience, whether pensions-related or otherwise, may also have provided individuals with transferrable skills. An over-emphasis on the testing of formal knowledge would risk overlooking the importance of these wider competencies.

Another part of the challenge is how to ensure that all trustees, not just those boards that are already well-governed, are aware of the latest regulatory guidance and industry best practice. To achieve this, information must be communicated in a way that ensures key messages reach the stakeholders responsible for pension schemes of all sizes and types.

Trusteeship should be considered at the level of the board as a whole

Trustees’ skills and capabilities should always be assessed at overall board level, whether the scheme has professional trustees or not, as all will have different skill sets. In our experience, it is the unique blend of backgrounds, experience, skills and attributes which each trustee brings to the table that influences ultimate board effectiveness.

Specific consultation questions

Question 1: What do you think works well in the current trusteeship and governance system?

As highlighted in our General Comments, the current trusteeship framework provides flexibility and avoids excessive prescription. This has allowed a range of governance models to develop that are tailored to scheme specific circumstances.

While there may be scope for targeted improvements or additional guidance in specific areas, flexibility should not be regarded as a weakness in the current system. Any changes should build on the strengths of the existing framework, rather than attempt to replace it with a more rigid, “one-size-fits-all” approach that may not be suitable for the full range of governance models and scheme types.

An approach that supports and empowers trustee boards to reflect on their effectiveness, rather than imposing additional prescriptive requirements, may be more appropriate. In many respects, this principle of self-reflection is already seen in schemes’ engagement with the “Own Risk Assessment” (ORA). It may be worth considering whether aspects of the ORA process could be adapted or repurposed as a means of evidencing sound trusteeship and governance. For example, through a requirement to confirm completion of an ORA via the annual scheme return in a manner analogous to the chair’s statement.

Finally, there could be a risk of an inherent tension between an aim to raise standards through individual trustee accreditation (and the perceived need for a high level of technical knowledge, previous pensions experience and “soft skills”) and the goal of ensuring diversity (as noted in paragraph 47 of the consultation). This needs to be factored in when developing policies aimed at improving both the quality and diversity of trustee boards as a collective group.

Question 2: What are the barriers to good trusteeship?

The main barriers to improving trustee capability are often time and resource. Trusteeship can represent a significant commitment and anyone taking on the role needs to be able to devote sufficient time to do it justice.

Unless a lay trustee (such as a member-nominated trustee) is employed by a sponsoring employer, they may not benefit from paid time off to fulfil their trustee duties. This can limit the time available for the role and may act as a deterrent to otherwise capable individuals putting themselves forward for appointment. There can also be constraints for employed trustees due to competing calls on their time.

Linked to this is the increasing complexity of pensions regulation and governance, which has materially increased the demands placed on trustees over time. This emphasises the importance of ensuring that any additional statutory or regulatory requirements which demand trustees’ time and attention are proportionate, clearly targeted, and deliver demonstrable value.

Another potential area to consider relates to the capacity of the trustees’ executive support. Capacity crunches can occur when several legislative and regulatory changes are happening at once (or in quick succession) or when unexpected issues arise which the executive support team need to resolve. In these situations, trustees and their support teams need to work together to set clear priorities, if acquiring short-term additional resource is not feasible.

There will inevitably be periods where rapid change in pensions law and regulation are unavoidable. However, where feasible, it would be helpful if a single specific regulatory area, or connected areas, could be focused on, with support from detailed guidance and thought leadership to help drive best practice. Providing stakeholders with sufficient time to assimilate a set of changes before the next development comes along is also helpful.

A lack of recognition of the crucial role trustees play could also act as a disincentive to volunteers. Obviously, a scheme’s sponsoring employer is significant in terms of ensuring that performance of the trustee role by its employees is seen as valuable within the business. This makes it especially important to continue supporting and encouraging all involved in pension schemes (including sponsoring employers) to recognise the value of good trusteeship through ongoing messaging and engagement.

Question 3: Looking ahead to 2030 and beyond, what further support will trustees need to ensure effective scheme governance?

Question 4: Does effective scheme governance in a Megafund require additional support or any specific changes in regulatory approach?

Looking ahead, effective governance will continue to depend on having the right people, supported by appropriate resources and advice. In parallel, it will be important for legislation and regulatory expectations to evolve over time whilst remaining proportionate.

In this context, it is worth considering whether the current regulatory framework places sufficient emphasis on the trustee board’s strategic role. Effective governance requires trustees not only to meet immediate legal and regulatory deadlines, whilst being capable of responding to the unexpected issues that can inevitably arise, but also to set proactive strategic objectives over the longer term and be able to identify and manage risks appropriately. As it is difficult to predict with certainty what the most significant governance challenges and priorities will be by 2030 and beyond, an approach that is adaptable and responsive to emerging issues is likely to be more effective in supporting high-quality trusteeship over that timescale.

To help avoid the risk of trustee boards being driven towards more reactive and compliance-driven tasks over proactive, strategic decision-making, the legislative and regulatory burden needs to be proportionate. Regulatory guidance, including the General Code, can play an important part in providing critical support to trustees in navigating this increasingly fine balancing act.

Not least because of their envisaged size, the proposals around DC Megafunds will bring their own unique challenges to the pensions market. Responsibilities of the parties involved will need to be clearly demarcated and, as with the existing master trusts regime, the level of accountability attached to certain roles will be key.

Finally, with many very large DC Megafunds being run by insurers / providers and pensions being part of a wider family of investment choices, products and services, the commercial aspects of running a scheme could become increasingly important to the work of trustees. It may be that, in future, some of those commercial factors could become increasingly influential over the resourcing, scoping and sequencing of certain trustee activities.

Question 5: Can you describe any potential or actual conflicts of interest that stem from the provision of further services within professional trustee firms and other third-party providers? How are these conflicts managed now? What is the scale of the residual risk in the market?

Question 6: Are additional safeguards needed to effectively manage these risks, given the need to balance members’ interests with effective scheme management?

Question 7: Should there be restrictions on individuals acting as professional trustees, such as the number of trustee appointments they can hold, to ensure individuals have the appropriate capacity to manage schemes?

Different solutions are needed for different circumstances and, for the reasons outlined below, it is likely to be difficult to design specific restrictions which achieve their goals whilst avoiding unintended consequences.

Professional trustee firms do not follow a “one-size-fits-all” model, with variations in terms of ownership structure, infrastructure and approach, including the types and numbers of appointments a given organisation will take on. The trusteeship business model has evolved considerably over the last decade or so, with some of the larger firms introducing graduate programmes and mapping out career paths. As per our “General Comments”, this is reflective of the diverse nature of trusteeship within the pensions industry, and we come across and work effectively alongside all different varieties of model.

The provision of additional services by professional trustee firms or other third-party providers can create potential advantages. For smaller schemes, a bundled service can provide efficiencies, reduce administrative burden and costs, and improve access to expertise that might otherwise be unavailable or unaffordable. However, as scheme scale increases, so too does the potential exposure to the risk of adverse outcomes arising from potential conflicts not being appropriately managed.

When appointing advisers, many schemes undertake a transparent and competitive procurement exercise. An appointment to provide “bundled services” on this basis is likely to involve a rigorous comparison of the services on offer from a number of providers. In contrast, where services grow organically from an initial trusteeship appointment this process may differ.

Of course, decisions here may be driven by expediency, familiarity, or the perceived benefits of continuity. As a result, the appointment of a bundled service provider may represent the best solution in all the circumstances for the scheme in question. But the heightened perception of conflicts where professional trustee firms are providing multiple services needs to be acknowledged and managed. The risk of potential conflicts not being appropriately managed could be higher where there is a sole PCST as, unlike a professional trustee sitting as part of a more diverse board, they cannot recuse themselves from any discussions on an appointment. However, trustees’ fiduciary duties provide an important mitigant to any such potential conflict or perception of conflict.

As the consultation recognises (paragraph 24), trustees are already subject to well-established requirements to identify, manage and document conflicts of interest. When properly applied, these controls are effective. As a consequence, we would encourage proportionate regulatory expectations that reinforce good procurement and conflict management practices, rather than blanket restrictions.

Trustee appointments can be linked to achieving a specific goal or carrying out a specific project. There may be scope for greater education and support for sponsoring employers around their obligations when appointing professional trustees, including the purpose of that appointment and the factors to be taken into account. In particular, this could encompass ensuring that there is understanding of the duties owed by trustees when setting expectations. More broadly, this highlights the value of providing appropriate support to all key stakeholders involved in the wider governance framework.

As regards the possibility of restricting the number of appointments individual trustees can hold, trustees (whether lay or professional) must be in a position to dedicate ample time to fulfilling their duties effectively. However, the time commitment of an appointment will vary depending on a scheme’s size, complexity, stage of evolution, and the particular tasks or projects on the horizon. Setting a limit on the number of appointments could therefore produce some arbitrary results, potentially imposing constraints on individuals with capacity whilst ostensibly allowing others whose time is scarce to take on new trusteeships. It seems to us that this question may therefore be best left to individual discretion, subject to some general guidance principles.

Finally, some professional trusteeship models involve sharing certain appointments among multiple individuals. Imposing a hard cap would not make sense in this scenario.

Question 8: Are there situations where a PCST model is more or less appropriate and why? Should there be any restrictions or suitability guidelines on PCST appointments?

In our experience, a PCST model can be particularly useful in a range of different scenarios and is a valid governance model for delivering effective trusteeship. For example, it can work well for specific projects or smaller schemes heading towards or in “end game” territory, in situations where it is difficult to obtain member representation on the board, or where there are no other candidates willing or able to stand. We have also seen it work well for schemes which are in a steady state. As the consultation suggests, using a PCST can be valuable where a particular skill set or a more streamlined decision-making approach would be beneficial.

Some professional trustee firms are more targeted towards PCST work than others. We are aware that many firms structure their teams and back-office functions to support the PCST role, including using deputies and/or in-house teams to provide diversity of thought and/or checks and balances. Such structures provide important ways of mitigating the potential risks identified by the consultation.

We support the work TPR is doing to find out more about these arrangements and would be supportive of any related guidance that is issued which explains to other stakeholders (sponsors and members) how the PCST model works and the governance that sits behind it.

Question 10: Given the future landscape for pensions, are any further controls or safeguards needed on the appointment of trustees to ensure that decisions are made in members’ interests?

In our experience, trustee boards are well run and make sound decisions in members’ interests, informed by appropriate professional advice. We are also seeing an increasing focus across schemes on the overall composition of trustee boards, including the balance between employer-nominated, member-nominated and professional trustees. The expected behaviours set out in the General Code provide helpful guidance.

Trustee boards will generally think about and look to address “skills gaps” on an individual and collective basis. This has evolved into a move towards more structured selection processes, with greater emphasis on achieving an appropriate mix of skills, knowledge and experience, as well as effective succession planning. These developments suggest that continued encouragement of good practice underpinning overall board composition, diversity, skills and forward planning, rather than additional controls or safeguards on trustee appointments, may be the preferable way forward.

Question 11: What role can government and regulators play in helping schemes to attract a diverse and talented pool of individuals to trusteeship?

We welcome the drive towards greater diversity and inclusion on trustee boards. In our view, a diverse board is more likely to combine a range of skills, ask challenging questions, and avoid the risk of “group think”. This is why care needs to be taken when weighing up whether or not to introduce an accreditation scheme for lay trustees, which risks jeopardising the number of potential candidates.

TPR’s two EDI guidance notes, aimed at governing bodies and employers respectively, already highlight the benefits of improving diversity and underline its expectations in this area.

Question 12: Should there be any limits on length of trustee appointment, or should they be limited in number of repeat appointments to the same trust?

In our view, there are inherent risks in imposing mandatory limits on the length of trustee appointments. Fixed terms could lead to undesirable outcomes, for example, where a chair or key trustee reaches the end of a prescribed term in the middle of a major project (eg a scheme wind-up) or where they possess significant scheme knowledge not shared by others on the board or the scheme’s advisers. For smaller schemes in particular, the loss of knowledge when a key person steps down could be significant.

Rather than setting uniform limits across all schemes, a more proportionate approach might be to require schemes to set and maintain their own policies on length of trustee appointment, with an expectation that these are followed so far as practicable and reviewed regularly. This would allow trustee boards to balance diversity, continuity, and succession planning in a way that reflects their specific scheme circumstances.

Question 13: Would it be appropriate to introduce a new public trustee who could be appointed by TPR? If so, in what circumstances would a public trustee appointment be preferable to a professional trustee from TPR’s independent trustee register? And why?

We are not sure that giving TPR a new power to appoint a public trustee would enhance its existing powers, ie to appoint a professional trustee in certain circumstances.

A new public trustee appointed by TPR might have a role in a limited set of circumstances, particularly for smaller schemes experiencing acute governance difficulties or challenging scheme circumstances, where early intervention may be beneficial and existing intervention powers have not yet been triggered. Given the complexity and sensitivity of the situations in which a public trustee is most likely to be appointed, an appointee would need to have a high level of experience and expertise.

However, there are also potential drawbacks that warrant consideration. For example, a trustee operating exclusively in this capacity may, over time, develop a narrower range of experience (eg focused primarily on distressed or high-risk schemes). In time, this could limit a public trustee’s exposure to wider market developments and emerging good practice across the pensions landscape. This possible drawback would need to be addressed (for example, through ongoing training or by encouraging diversity of appointments to maintain breadth of experience) if a public trustee model were to be introduced.

Question 15: How can TPR ensure it has the information it needs for the directory without creating greater administrative requirements for schemes?

It would be helpful to know more about how TPR intends to use the information collected for the purposes of the new directory, and the specific outcomes intended. As the consultation recognises, there is a balancing act required here between enabling TPR to collate the information it feels it needs and not significantly increasing the administrative burden across the board.

We can see that monitoring trustee activity, and allowing better engagement and support, would be beneficial to TPR and trustees. However, it is not immediately obvious that the trustee directory would necessarily “flag up” those schemes requiring “targeted intervention”. We would welcome further detail on the information that would form part of the directory to enable this, and how this would be assessed. In particular, the presence or otherwise of a professional trustee should not, in and of itself, be regarded as an indicator of governance levels, as outcomes depend on a broader range of factors.

If the intention is for the directory to support monitoring of TKU requirements, this would require sufficient regulatory resource to review the information (which will inevitably include personal data) collected regularly and to take action where needed. There could also be practical challenges in maintaining an accurate and up-to-date directory over time.

In terms of available options for minimising the additional administrative burden for schemes, incorporating any required information into existing reporting mechanisms seems to us to be the most straightforward approach. For example, collecting required data via the annual scheme return rather than introducing a separate standalone reporting process.

Question 16: What skills will trustees of trust-based pension schemes need in order to be an effective and efficient trustee board? For example, areas such as leadership experience, negotiation skills, investment management, (including sustainability-related investment management), communications, financial planning? What other areas should trustees have proficiency in?

We agree that skills in areas such as leadership, negotiation and investment management, communications and financial planning are all important within an effective trustee board, alongside the ability to identify and manage risks appropriately. In addition, depending on the scheme type, knowledge of the business and its history from both the employer and member perspectives can be invaluable, especially where the scheme is mature with a high number of deferreds and pensioners.

However, as indicated under our General Comments, it is important to recognise that an effective board is the sum of its parts, and it is neither realistic nor necessary for every trustee to possess expertise across all core areas. Certain skills, particularly around leadership, facilitation and decision-making, may be more critical for the chair than for each individual trustee.

Given the vast array of legal and regulatory requirements occupational pension schemes are subject to, trustees are not (and should not be expected to be) pensions experts. The division of responsibilities in occupational pension schemes, between “experts” giving advice on the one hand and trustees as appointed “decision-makers” reaching a conclusion having considered all relevant input on the other, is integral to good governance processes.

In addition, some of the schemes we advise delegate specific tasks to sub-committees, such as investment and corporate event planning, with some sub-committees seeking input from non-trustees before making recommendations to the overall board. Whilst the ultimate decision-making rests with the trustees, having weighed up relevant factors, this approach can be useful.

Question 17: Would it be appropriate for TPR to set statutory higher standards for professional trustees? What should these standards look like?

Professional trustees do not all perform the same role; some act as chair, while others serve on mixed trustee boards alongside lay, professional or other independent trustees. Some also adopt the PCST approach. Schemes also have different circumstances and needs.

A single set of higher statutory standards for all professional trustees may therefore be neither proportionate nor effective. It may be more appropriate to apply enhanced standards to specific roles, such as chairs, where governance leadership and decision-making responsibilities are greater. Any standards introduced would need to be clearly defined, outcome-focused, and proportionate. However, for the reasons outlined in our General Comments and our response to question 1, introducing a single set of standards could be challenging.

Similarly, any differentiation in standards would require a clear delineation between professional and non-professional trustees, which in and of itself could prove problematic. In attempting to set different standards for different types of trusteeship, account would need to be taken of the fact that all trustees are generally subject to the same legal and regulatory requirements, and a trustee board is collectively responsible for the decisions it makes. Setting different levels of statutory standards could appear to be at odds with that fundamental principle.

That said, trustees who hold themselves out as having a particular skill or expertise are already held to a higher standard of care. Trustee protections in scheme rules also tend to make this distinction, as do the anti-money laundering requirements where a trustee is carrying on business. Likewise, TPR expects higher standards from professional trustees.

Question 18:  We are moving towards models of trusteeship that do not include as many lay trustees as now, what important benefits or skills of lay trustees should we try to replicate in consolidated structures? And how should it be achieved? 

The traditional strengths of lay trustees include their ability to ask challenging questions, view issues through a member lens, recognise when advice or communications need to be simpler, clearer or more accessible, as well as helping to manage potential for conflicts of interest. Such considerations, as well as the fact that members may be “less likely to be suspicious or critical of decisions taken by the trustee board if they know that trustees appointed by them were involved in the decision-making process”, helped shaped the introduction of the member-nominated trustee / director obligations (“MNTs” / “MNDs – see eg paragraphs 4.5.23 to 4.5.26 of the Goode Report (1993)).

In our experience, lay trustees (whose experience, skills and perspectives may differ materially from those of professional trustees) therefore perform an important role on balanced and high-functioning trustee boards.

In addition, lay trustees often bring skills and insights from their employer roles to the table, which those who work solely in the pensions industry may not necessarily possess. For example, lay trustees who are employees will generally have valuable knowledge of the sponsor’s business. A reduction in lay trustees could risk trustee boards becoming more insular, inward-looking and less readily attuned to issues beyond the pensions industry.

Any consolidated structures could aim to replicate these perspectives and skills, for example through targeted training, advisory input from member representatives, or mechanisms to ensure trustee boards retain a strong connection to member and employer viewpoints.

Question 19: What support/continuing professional development (CPD) would you like to see put in place for lay trustees? Should all trustees be accredited? Would it lead to a trustee shortage? Who would pay for it including time as well as any L&D costs?

We do not think it would be appropriate or effective to require all trustees to be accredited. In our view, the existing TKU framework is serving its purpose and striking the right balance. As noted in our General Comments, effective trusteeship relies heavily on skills and judgement that are not easily accredited. Mandatory accreditation also risks deterring capable candidates, which could work counter to the objective of increasing diversity on trustee boards.

Expected behaviours set out in the General Code encourage trustees to conduct self-assessments of their TKU and training needs. In our experience, trustee boards are increasingly designing their own minimum CPD requirements, and putting in place training plans which are tailored to the scheme and its journey plan.

In practice, we are also seeing examples of good support for lay trustees that focus on development and empowerment rather than formal accreditation. These include a focus on training for new trustees, one-to-one sessions with the chair to discuss how trustees are finding their role and whether they have the skills, support, and confidence to contribute effectively, alongside clear expectations around training and learning registers. Making these resources accessible helps trustees feel supported and reassures potential candidates that they will receive guidance if they take on the role.

That said, it is important for lay trustees to appreciate that trusteeship is a significant commitment and to be realistic about the responsibilities involved. In our experience, the overwhelming majority of trustees, both lay and professional, are dedicated and motivated by a genuine desire to act in member interests. As already indicated, we would caution against introducing top-down prescriptive requirements that could reduce the pool of trustee applicants and/or risk demotivating individuals already in place.

Question 20: How can we ensure trustee boards take into account the perspectives of members in their decision making?

Approaches to taking member perspectives into account will naturally vary from scheme to scheme, depending on factors such as scheme size and resources, as well as the particular stage of its journey. Member views might be sought on certain topics, such as in DC schemes, the factors influencing decisions about their pensions and on communications. But, in our experience, pension schemes do not routinely seek direct member views, although input might be channelled indirectly through MNTs / MNDs.

However, where feedback is sought, there are two primary approaches boards tend to follow:

  • direct engagement with members – for example, through events, workshops, or one-to-one conversations. This may be more feasible in smaller schemes or where there are sufficient resources to support meaningful engagement, and/or
  • representation through members themselves – for example, member-nominated trustees who act as a proxy for the wider membership and bring their knowledge of member perceptions into board discussions.

In schemes without member-nominated trustees, employers often have employee forums or other representative bodies, which boards could tap into to understand member views. Overall, maintaining channels for both direct engagement and representative input can help to ensure trustees consider member perspectives.

It is important to recognise that member feedback sometimes comes from a relatively small proportion of engaged members and may not fully reflect the views of the wider membership.

Question 21: Can you give any examples of best practice in the UK or internationally that demonstrate schemes taking appropriate account of their members’ views?

Best practice examples include holding workshops, member events, and one-to-one sessions to gather feedback. While surveys can provide useful data, approaches involving direct engagement and interaction can provide trustees with a better understanding of member needs and concerns. However, they can also entail significant resource and cost, and their feasibility will depend on the scheme’s size and capacity.

  1. What benefits and challenges do you foresee if mandatory minimum standards were introduced for scheme administrators and/or wider administration services such as Integrated Service Providers? 
  2. Should TPR have the same levels of regulatory oversight as the FCA regarding administrators and/or wider administration services, and why?
  3. Should administrators have to be registered with TPR to be involved in administering a scheme? If so should TPR be able to deregister an administrator? (A model similar to that in Ireland) 
  4. What risks if any, does increased levels of consolidation activity in the DC sector pose to administration service providers? How can these risks be mitigated to ensure an orderly transition to Megafunds?

The consultation focuses on a number of important issues affecting scheme trusteeship and good governance. Whilst administration is a key cog in that wheel, this is a very broad and important area in its own right.

We welcome the work that the DWP and TPR are doing to focus on administration, which is fundamental to good member outcomes and the successful implementation of future changes. Given its importance, we likewise agree that the risks associated with provider failure would be material and are supportive of work being undertaken to assess and mitigate this risk.

The platforms being used by pension scheme administrators to conduct business need to be borne in mind. Technology and systems will differ between administrators and, even within the same organisation, depend upon the history of a particular administrator / scheme. Technology being used in a given case may not therefore be compatible with new policy or legislation being devised, with time and resource needed to adapt and test capability and functionality. This could present an initial barrier to implementation. Given the speed at which technology evolves, it seems increasingly likely that this could impede activity in the future – particularly in a market which is consolidating whilst grappling with layers of historical legacy platforms.

Resilience and capacity are also key areas of concern, and we recognise the importance of administration providers, as well as data and platform providers. We would support a fuller consultation on administration which could draw out these themes in more detail and seek input from the providers operating in this space as to how these risks can be managed.

We are likewise supportive of the tie-up between TPR’s administration guidance (issued in December 2025) and various PASA publications. The challenge for trustees is how to understand, oversee and get the best out of their administrators. We have been involved with the PASA trustee focus group working to produce related guidance, with Part 1 of their new four-part trustee–administrator life-cycle series (“Why Trustee–Administrator Relationships Matter”) published very recently. PASA’s role in the industry is pivotal here and this guidance will be immensely helpful.

The challenge of mandatory minimum standards is the breadth and variety of schemes and benefit structures to which they will apply. As a result, they are likely to be either so high-level or generic as to be of limited value, or so detailed as to be impracticable to document, report against and/or monitor. That being said, we are supportive of regulatory oversight of, and building closer ties with, administrators who perform a vital function to the industry. This should include in-house administered schemes, as well as third-party providers.

Consolidation in the third-party administrator (“TPA”) market has been happening organically for many years, and the proposed changes to the DC sector are likely to be a driver for further amalgamation. Resilience is not directly linked to scale, and indeed not all TPAs will choose to operate at scale. Similar to the professional trustee market, in our experience, there is a great variety of models of administration businesses and that is likely to continue.

In conclusion, we believe that the issues raised concerning administration, including the key risks involved and how these can be best mitigated, merit their own separate, dedicated consultation. This would allow full consideration of relevant issues, taking into account existing guidance and ongoing work by PASA in defining what good administration looks like, and in helping to support and raise overall standards.