Pension SuperFund and Disruptive entities
FOI reference - FOI-454
Date - 3 February 2026
Request
- All information provided to The Pension Regulator by Mr Edmund Truell’s Pension SuperFund and Disruptive entities (We understand Mr Truell’s Disruptive Capital GP Limited and Disruptive XI LP (and any other ‘Disruptive’ entities) are part of Mr Truell’s Pension SuperFund (all ultimately sitting underneath Pension SuperFund Capital Holdings Limited)) during the assessment process for each of its three applications for regulatory approval to operate a ‘pension superfund’ in the UK, including but not limited to Pension SuperFund’s asset valuations and its compliance with The Pension Regulator’s expectations for asset valuations by superfunds, as outlined in 7.3.4 (Capital release) of the DB superfunds guidance (Or the equivalent guidance on asset valuations at the date of each application by Pension SuperFund);
- Any comments made by The Pension Regulator to Pension SuperFund (or any of its affiliates or advisors) in response to those applications;
- Any assessments made by The Pension Regulator as to Pension SuperFund’s applications for regulatory approval, including but not limited to Pension SuperFund’s asset valuations and its compliance with The Pension Regulator’s expectations for asset valuations by superfunds, as outlined in 7.3.4 (Capital release) of the DB superfunds guidance.”
Response
I confirm that we hold the information you have requested. However, the information is exempt from disclosure.
Section 44(1)(a) – restricted information under s82 PA04
As we have been given strong powers to demand documents and other information from trustees, employers and others, those powers are also balanced by restrictions on how we disclose the information provided to us. The information you have requested is ‘restricted information’. Restricted information is defined at section 82(4) of the Pensions Act 2004 (PA04) as:
‘…information obtained by the Regulator in the exercise of its functions which relates to the business or other affairs of any person’.
Under section 82(5) of the PA04 it is a criminal offence to disclose such information except as permitted under that Act.
Whilst the FoIA is based on the presumption of releasing information, section 44(1)(a) of the FoIA provides an absolute exemption to the requirement to disclose any information if its disclosure is prohibited by or under any enactment. In this case, section 82 of the PA04 prohibits disclosure and we are unable to disclose the information requested. This includes any TPR comments on, or assessments of, the application which are inextricably linked with the application and are thus covered by the prohibition. This exemption is absolute and does not require a public interest assessment be undertaken.