Reports of material payment failures 2021 to 2022
FOI reference – FOI-491
Date – 10 August 2026
Request
Under the Freedom of Information Act 2000, I request the following information relating to reports of material payment failures concerning workplace pension contributions.
For each financial year from 2021/22 to the most recent year for which data is available, please provide, where held as recorded management information:
- The number of material payment failure reports received by The Pensions Regulator (TPR).
- Of those reports, the number of cases in which the employer subsequently made good the reported contribution shortfall, where this outcome is recorded.
- The number of cases in which TPR took formal enforcement action following a material payment failure report.
- The number of cases that remained unresolved at the end of the relevant financial year, where this status is recorded.
- The number of cases in which TPR issued an unpaid contributions notice following a material payment failure report.
Please provide aggregate figures only. I am not requesting the names of employers, individual pension schemes, employees or individual cases.
Please use TPR's existing definitions and classifications for material payment failures, enforcement action, unpaid contributions notices and case outcomes.
I am requesting existing recorded information only and am not asking TPR to calculate the monetary value of outstanding contributions, match individual cases against external datasets, review individual case files or undertake bespoke analysis.
If any of the requested information is not held in a readily available aggregate form, please provide the remaining information that is held in aggregate form without undertaking additional analysis.
If any of the requested information is already publicly available, please direct me to the relevant publication and provide any remaining information that is not already published.
I would be grateful if the information could be provided in Excel or CSV format where possible.
Response
Under section 12 of the FoIA public authorities are not obliged to comply with a request for information where the cost of complying would exceed the appropriate limit in the Fees Regulations, which, for us, is set at £450. Staff costs are fixed at £25 per person per hour. This represents the estimated cost of one person spending 18 hours in determining whether we hold the information, locating, retrieving, and extracting it.
We can confirm that the information you have requested is held, but in line with section 12 of the FoIA we are not able to provide the information to you because this would take us at least three hours in excess of the applicable time limit to determine whether the appropriate material is held and to locate, retrieve and extract that information. Below is a breakdown of the estimated time required:
- Determining whether the information is held – Approximately 30 minutes to consider the request in detail, liaise with colleagues for input, and then determine that we have the data.
- Locating the information or relevant documents – Approximately 15 minutes to check whether there is any archived aggregated data for the five years in question that could be used to answer the questions. We do not hold any such data.
- Retrieving the information – Approximately 14 hours to ‘Retrieve the information’, which in this instance means that we would have to write some Structured Query Language (SQL) code to extract the information from our databases. There are some existing SQL code sets that we could use, but they would need combining into one set of code, testing, amending and re-running until such point as the code works with no errors and the output looks reasonable. Based on work carried out already to try and achieve this, a further estimated 14 hours would be needed.
- Extracting the information from a document containing it – ‘Extracting the information’ is effectively part of the process of running the SQL code, as the code is written in such a way that it compiles and analyses the raw data and carries out the calculations to produce the final output. Quality assurance will need to be carried out on the SQL code and the output. Given the complexity of the code and the amount of data involved (>3.5m rows), this would take another estimated 6 hours.
Total estimated time: approximately 21 hours
Having carefully considered your request, we are not able to provide any of the requested information within the appropriate cost limit.
This is because most of the work required relates to extracting and manually reviewing a very large volume of data, over 3.5 million rows, by way of customising SQL code before testing and quality assurance of the output. While narrowing the scope of the request, for example by reducing the number of financial years or criteria, may reduce the volume of data returned, it would not remove the significant coding, testing, quality assurance and manual review activities required to identify and extract the information.
Duty to provide advice and assistance
In line with our duty under section 16 of the FoIA, we have considered what advice and assistance we are able to offer. As mentioned above, given the breadth of information originally requested, we are not able to say with confidence that a revised or narrower request would necessarily fall within the cost limit, and we would not want to give the impression that a resubmission is guaranteed to succeed.
Any future request will be considered on its own merits, taking into account the specific information sought and the resources required to locate, retrieve and extract that information. Where information is held and can be provided within the appropriate limits set out under the Act, this will be considered at that time.