TPR launches campaign to prepare trustees for 'new chapter' under Pension Schemes Act

The Pensions Regulator (TPR) has launched a multi-year campaign to help defined contribution (DC) schemes prepare for higher governance and member outcome standards under the Pension Schemes Act 2026.

In a blog, the regulator said the new requirements mark a "new chapter" for DC schemes, with trustees expected to focus on delivering better outcomes from members' first contributions through to retirement.

The campaign will include direct communications to trustees, practical guidance, examples of what 'good' looks like, and engagement with advisers, administrators and the wider market.

TPR has also launched a new Pension Schemes Act webpage, which will be updated as details of secondary legislation become available.

The first phase of the communications programme began this week, with emails being sent to trustees of schemes providing DC benefits that are not expected to be exempt from the new requirements.

The emails will encourage trustees to assess their ability to comply with the new standards and begin preparing for future regulatory requirements.

TPR said further communications will be issued as requirements evolve, while roadmap publications from the Department for Work and Pensions (DWP) and TPR are expected shortly, setting out more detail on the act's implementation.

TPR director of DC and master trust supervision, Kim Goodall-Brown, warned that trustees "cannot afford to stand still" following the passage of the Pension Schemes Act.

"Our vision is clear: sustainable and adequate retirement income for everyone," she said.

"But with 15 million heading towards an insecure future, there are challenges to face down."

The Pension Schemes Act introduces a number of new legal duties for DC schemes, including value for money (VFM) assessments, requirements to provide default guided retirement solutions, small pot transfer obligations and minimum scale requirements for DC master trusts.

Under the VFM framework, trustees will be required to assess default arrangements using prescribed metrics and compare performance against the wider market.

Schemes will also need to provide a default decumulation pathway to support members into retirement, while automatic enrolment schemes must be able to facilitate transfers of deferred small pots worth £1,000 or less after 12 months without contributions.

In addition, DC master trusts will be required to hold at least £25bn in assets under management in a main scale default arrangement from 2030, with a transition pathway for schemes that need longer to reach scale.

Goodall-Brown noted that the reforms would change the dynamic for DC trustees, who have traditionally focused on accumulation and, in many cases, prioritised low costs over broader value.

"From the first contribution through to retirement, there are higher expectations on trustees to achieve better outcomes," she stated.

TPR also warned that not every scheme will meet the new standards, noting that its data shows master trusts and larger single-employer schemes are better placed to deliver good outcomes.

Goodall-Brown said smaller schemes could still deliver good outcomes, but stressed that the bar is rising.

"Operating a smaller scheme is becoming more complex, more demanding, and more resource-intensive.

"The market is consolidating rapidly. The inescapable trend is towards fewer, larger schemes that can deliver stronger investment performance, higher governance standards and an improved member experience."

Indeed, TPR's 2025 DC landscape data showed 15 per cent fall in the number of non-micro DC and hybrid schemes over the past year, with the decline concentrated among schemes with fewer than 5,000 members.

The regulator stressed that trustees should now assess whether their schemes can meet the higher legislative standards, or whether members would benefit from consolidation into a scheme with greater scale, value and governance.

Where trustees decide to continue running a scheme, TPR said they should be ready to demonstrate strong governance, reliable data, a clear path to meeting the new requirements and a credible way to support members into retirement.

Goodall-Brown also suggested schemes may need external support to strengthen administration, governance or retirement income options.

She said employers should work with trustees on the future of their scheme, while administrators should facilitate and enable compliance.

"The direction is clear: stronger governance, better data and supporting members into retirement are now essential," she stated.

"Review your scheme. Close gaps quickly. If they are too large, consider if another route could serve members better.

"The key question is not 'can we carry on as we are?' but 'what is the best route to good outcomes for members?'

"Our message is to start now, consider the options, and act in your members' best interests."



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