The Society of Pension Professionals (SPP) has launched a practical governance framework to help pension scheme trustees oversee the growing use of artificial intelligence (AI) across administration, investment, advisory services and member communications.

The guide, Governance in the Age of AI: A Practical Framework for Responsible Leadership, warned that AI adoption had accelerated faster than the development of dedicated regulation, with the SPP’s annual surveys finding that 87 per cent of pension firms used AI in 2025, rising to 100 per cent in 2026.

However, the SPP stressed that trustees’ existing fiduciary, governance and risk-management responsibilities continued to apply, regardless of whether decisions were informed by AI-enabled tools or delegated to providers using AI.

With this in mind, the framework is built around five principles: transparency, accountability, proportionality to risk, security by design and meaningful human oversight.

It recommended that schemes classify AI use as low, medium or high risk, and urged them to consider creating an AI register covering current use cases, ownership, approval processes, review frequency and the management information provided to trustee boards.

The SPP said particular care was required where automated decision-making was involved, suggesting that automated decisions affecting benefit entitlement, calculations, personalised retirement communications, case prioritisation or the suspension of payments could require additional safeguards.

It stressed that automated decision-making was unlikely to be appropriate for ill-health or incapacity decisions because of the sensitive data, medical judgement and financial consequences involved.

The SPP also urged trustees to seek assurance that providers had protections against AI-enabled fraud, including deepfake impersonation, voice cloning, fraudulent instructions and AI-generated phishing.

Meanwhile, the framework warned that public AI tools could create data-security and confidentiality risks if trustees or members uploaded scheme documents, benefit statements or other personal information.

It therefore recommended improving scheme communications, providing warnings about the limitations of public AI tools and maintaining accessible routes to human support.

SPP Administration Committee chair, Jo Fellowes, noted that AI had become an everyday feature of the pensions industry.

“The challenge is therefore not whether AI should be used, but how it can be used safely, transparently and with appropriate oversight. This SPP guide should help schemes achieve this.”

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