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The UK’s Pensions Regulator (TPR) is seeking to accelerate pension scheme consolidation to raise governance standards. 

In a consultation paper launched today, TPR said it wanted to ensure all pension savers were in schemes with “excellent standards of governance that deliver good value” – which would mean “fewer but better governed schemes”.

The regulator’s consultation, titled The Future of Trusteeship and Governance , set out a number of questions and proposals aimed at improving trustees’ knowledge and understanding. 

Among the areas being explored by TPR were diversity on trustee boards, a potential requirement for every scheme to have at least one professional trustee, and higher training and qualification requirements for all trustees.

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David Fairs, executive director of regulatory policy, analysis and advice at TPR, said there was “a subset of disengaged trustees that are either unable or unwilling to take action to improve scheme governance”.

Some trustees, particularly those responsible for the smallest schemes, “believe the standards don’t apply to them”, he added, while others treated their role as a pension fund trustee as “peripheral” or “symbolic”.

“Things need to change,” Fairs said. “We want all savers to have access to well-run schemes. The trustee model isn’t broken but it does need to work better. This will require attention from TPR, employers, advisers, trustee representative bodies and trustees themselves.”

Some consolidation has already taken place in the UK’s defined contribution (DC) market, mainly through multi-employer master trusts such as The People’s Pension and Smart Pension acquiring smaller schemes. However, TPR said there were still 32,000 “small or micro schemes”, including DC, defined benefit (DB) and other forms of pension fund.

TPR is working with the UK’s Department for Work and Pensions to set out a regulatory regime for commercial DB consolidators.

Fairs added: “There is stark evidence that the current system doesn’t work for all and there is a clear disparity between the experience of savers in well-run and badly-run schemes. If trustees cannot meet the standards we expect, we believe they should wind up and consolidate savers into a better run scheme.”

The consultation will be open for 12 weeks, closing on 24 September.

Industry reaction

Laura Andrikopoulos, head of governance consulting, Hymans Robertson

“We welcome this consultation as it opens up further industry debate on the standards of trustee knowledge and understanding (TKU), whether accredited professional trustees should sit on every board and whether the pace of DC consolidation for schemes unable to meet current standards is sufficient.

“While the merits of the new accreditation regime for professional trustees are as yet untested, in our experience many boards do benefit from having a professional trustee. They are able to bring wider market knowledge and a greater level of in-depth expertise to pension scheme trusteeship.

“The diversity that comes from the additional lay members on the board, however, is also valuable. Currently, for lay trustees not subject to the new professional standards and accreditation regime, there is little formal guidance for TKU requirements beyond the existing code of practice and the expectation of completion of [TPR’s] Trustee Toolkit within six months.”


Lesley Carline, president, Pensions Management Institute

“Given the number of pension scheme members suffering from poor scheme governance, this consultation is very welcome. It has pulled no punches in asking the hard-hitting and provocative questions that schemes and their trustees need to answer, positing pragmatic solutions to take the industry forward.

“As we strive for ever-improving standards of governance… we hope that many people proactively engage with this consultation to deliver better outcomes for members across the country.”


Vassos Vassou, professional trustee, Dalriada Trustees

“Raising scheme standards and governance for all pension schemes can seem like a never-ending challenge. The regulator’s consultation focuses on important areas such as trustee knowledge and understanding, diversity, sole trusteeship and consolidation of DC schemes.

“The consultation also raises the possibility of having a professional trustee on every board. This in particular would be something of a game changer for the industry improving governance standards and driving more robust discussions between boards, sponsors and the regulator.”

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