Pension trustees must not treat their first Own Risk Assessment (ORA) as a 'compliance exercise', Sackers has said, as schemes approach the earliest deadlines for completing the new requirement in March 2026.

The law firm noted that many schemes will undertake their first ORA this year and urged trustees to focus on the risks most relevant to their scheme, rather than approaching the process as a tick-box exercise.

Sackers partner, Helen Baker, said trustees should view the ORA as a meaningful governance tool that assesses whether scheme policies and procedures are working effectively.

“The ORA is not a tick-box exercise; trustees should evaluate whether policies and procedures are effective, meeting their objectives, and include clear processes for addressing issues where they arise,” she argued.

“Using real examples and highlighting areas for improvement will add real value to the process.”

Baker noted that, with no prescribed template from The Pensions Regulator (TPR), trustees may be considering how best to approach the exercise.

Drawing on Sackers’ work with trustees across a range of schemes, Baker stated that several key themes had emerged to guide schemes through their first ORA.

She stressed that trustees should first ensure the ORA is tailored to their specific scheme, noting that there was no single 'right' approach and governance needs would differ between schemes.

"Trustees should also ensure that risk identification, assessment and management are central to the process, including emerging risks such as cybersecurity and artificial intelligence, as well as areas of regulatory focus such as administration," she said.

Baker added that trustees should approach the ORA as a practical governance 'health check'.

“This is a new process, and everyone is learning. Trustees should focus on what is actually required and on the risks that matter to their scheme uniquely, while having a clear plan for work that still needs to be done,” she said.

“An ORA isn’t an exam; the goal isn’t to get the best mark. Instead, think of it as a health check for your scheme’s ESOG - a regular opportunity to look under the bonnet, spot any issues and ensure everything is running smoothly.”

She continued that because the ORA formed part of the scheme governance cycle, it provided trustees with a three-yearly opportunity to review governance and set priorities for the future.

“Even the best-run schemes are likely to find areas where recent developments, such as those relating to administration or cyber, mean there is more to do,” Baker concluded.

“Clear prioritisation, focus and planning will help trustees navigate the first ORA and set strong foundations for those to come.”

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