The Pensions Regulator (TPR) is urging UK trustees to treat member data as their “most important strategic asset” after an engagement exercise with “hundreds of schemes” revealed patchy standards ahead of pensions dashboards going live in less than a year.
A large-scale TPR engagement exercise has revealed that significant progress has been made to improve data quality in preparations for pensions dashboards. But TPR’s report has shown that some schemes still have more to do to get their member data in shape for pensions dashboards in less than a year’s time.
TPR highlighted that while most schemes have made progress on cleansing personal data for dashboards, value data – used to calculate benefits – is often overlooked. Improvement plans are frequently informal or fragmented, and trustee engagement ranges from proactive oversight to near-complete reliance on administrators.
The report also found that controls and trustee focus vary widely. In many cases, administrators lead data assessments with limited trustee scrutiny. It said that while data issues are being addressed by some schemes, a historical underinvestment in data management by others means the industry faces a ‘data debt’.
TPR research published in July found that one in four UK pension funds still hold some non-digitised records. And fewer than three in five are confident in the accuracy of the common data they hold on their membership.
Following its findings, TPR has today published revised member data guidance that consolidates all data-related guidance into one place and sets out “clearer expectations and provides best practice examples to help schemes achieve better data management capability”.
The guidance explains how:
- trustees are ultimately accountable for data quality, even if tasks are delegated to administrators;
- trustees must ensure regular data assessments, review reports, and submit accurate data scores in their scheme return;
- trustees should have a clear data management strategy, allocate resources for improvements, and challenge service providers where standards are not met;
- the regulator is now scrutinising the data preparations of the UK’s largest schemes and will expand its engagement in 2026. Trustees need to be ready to demonstrate how they are maintaining data, in line with legal requirements and TPR expectations. Pension funds unable to demonstrate compliance may face formal intervention, including improvement notices.
Julian Lyne, executive director of market oversight at TPR, said: “Good data is the foundation of good governance and a trustee’s most important strategic asset.”
Trustees are accountable for ensuring member data is correct – no one else, Lyne pointed out, adding that maintaining its quality is an ongoing responsibility.
He continued: “With the pensions dashboard deadline less than a year away, the need for reliable data has never been more urgent. The gaps identified in our report risk undermining dashboard readiness and highlight the importance of trustees adopting robust, consistent practices across all aspects of data management.
“Good data must be complete, accurate, timely, consistent, unique, valid and properly managed.”
The guidance from TPR was welcomed by the industry.
Helen Forrest Hall, chief strategy officer at the Pensions Management Institute (PMI), said: “We support TPR’s view that trustees must see data as a strategic asset and invest in the skills and relationships needed to manage it effectively.”
She said that without robust oversight and collaboration with administrators, schemes risk falling short on dashboard readiness and, ultimately, on delivering for savers.
Michelle Esterkin, head of admin consulting at Brightwell, added that data quality is “critical” to efficient, effective and resilient administration.
“Data management is not a ‘one and done’ and we welcome this guidance which clarifies what’s expected of administrators and trustees to ensure data is managed and maintained on an ongoing basis,” she noted.
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