The Pensions Regulator's (TPR) new record keeping guidance is not tough enough nor specific enough on how the new regime will be policed and reported on, says Independent Transition Management (ITM).

The data, administration consulting and IT support provider said the Regulator's latest guidance falls far short of what could have been possible, although it is a positive step forward.

The revised guidance still has a target of 95 per cent accuracy for legacy Common scheme data and has scheme specific targets for all Conditional data. Phillip Bretnall, director at ITM, said that TPR had said it would take a tougher approach on record keeping, although he has not gone far enough.

"The question is, would anyone accept 95 per cent accuracy in other areas of their life - bank accounts, for example? No, yet this appears to be accepted in the pension administration community."

Conflicts of interest are also raised by the Guidance, ITM said. One such issue is whether trustees can really expect their administrators to report on data with total objectivity. ITM would also have recommended stronger emphasis in trustee disclosure in the accounts.

Law firm Sackers commented that the Regulator's requirements are in fact too high.
"Whilst it may be helpful for schemes to have targets in relation to data we are concerned that the targets set by the Regulator may be unattainable, particularly in relation to legacy data," explained Zoe Lynch, associate at Sackers. "We expressed concerns about the targets in our response to the consultation, particularly as trustees are often in the hands of administrators on data issues. But the good thing to come out of the consultation is that at least the Regulator now recognises that some schemes will never be able to sort out their legacy data because of scheme specific circumstances, perhaps because records have been destroyed. In these cases it is helpful to know that the Regulator will listen to evidence on a 'case-by-case' basis."

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