Enforcement approach

Our enforcement strategic objectives, the approach we follow, the enforcement toolkit we use and how we decide to act.

Published: 8 September 2026

Our aim

Our corporate vision is for people to have a sustainable income in retirement. To realise that vision we are delivering our mission to protect workplace pension members’ money, enhance the pensions system, and support innovation and growth in members’ interests.

Good member outcomes drive our prioritisation, and enforcement is an important tool to ensure members receive security and value from the system, which in turn drives better retirement outcomes.

Our enforcement approach enables us to be transparent about our expectations and predictable in our actions. Through this we will engage quickly and proactively on issues that matter, before harm crystalises. We will act early, decisively and proportionately, adopting a risk-based approach, to prevent harm to members and the wider financial ecosystem.

Enforcement is one part of our broader regulatory approach that combines proactive engagement, clear expectations and the use of our full range of regulatory powers to improve outcomes for members and support a well-functioning pensions system.

Our aim is to deliver effective and efficient enforcement that:

protects members from harm
raises compliance and standards to enhance the pensions landscape
supports a pensions system that works in the best interests of members

Our enforcement approach sets out how we deliver our aims by outlining clear principles for when we investigate and how we apply our powers, whether regulatory, civil or criminal. It ensures we are equipped to respond to emerging risks, act decisively when standards fall short, hold people to account and deliver positive outcomes for members.

This approach represents a deliberate evolution in our enforcement. While building on our existing strengths, it introduces a more focused, agile and outcomes-driven model that is better aligned with the changing risks in the pensions landscape, with a stronger emphasis on delivering real-world results. Such results include improvements in member security, governance and administration standards, and confidence in the pensions system, alongside other benefits identified.

Our goal is not only to protect members and uphold standards, but to help create a pensions ecosystem that is strong, transparent and resilient. Resilience means a system that continues to deliver secure benefits for members over the long term and contributes to economic growth. As the pensions market consolidates and evolves, we will continue to use our powers to address wrongdoing and harm to members. At the same time, a smarter and more proportionate enforcement approach reduces unnecessary regulatory burden, encourages innovation, and builds confidence. Enforcement is not simply about responding to harm when it occurs. It is also about influencing behaviours, raising standards, and supporting a resilient pensions system that delivers better outcomes for members. Together, these create the conditions for a pensions system that works for members now and in the future.

At the very heart of an ecosystem of government, regulators and industry, we will use our position to drive forward our vision that everyone has a sustainable income in retirement.

Enforcement strategic objectives

Our enforcement approach is shaped by five strategic objectives, designed to support the wider aims of our corporate plan – protecting workplace pension members’ money, enhancing the pensions system, and supporting innovation and growth in members’ interests. This alignment helps us improve and promote good outcomes for members, and our objectives guide how we use enforcement to deliver our mission:

1. Targeted enforcement that tackles the key risks and harms to members with the greatest impact

We target enforcement where the risk to members is greatest, and where our actions can deliver the most impact, guided by our statutory objectives. In every case, we assess the level of actual or potential harm to decide the most appropriate action.

We monitor trends and evaluate outcomes to ensure our enforcement actions drive behavioural change, deter misconduct, and deliver meaningful benefits to members, particularly those who are vulnerable or at greater risk. This includes lower-income workers and members most likely to experience financial hardship in retirement.

We prioritise our enforcement activity based on impact, scale, and complexity, enabling us to focus on the issues that matter most, regardless of the regulatory regime.

2. Drive impactful enforcement through assertiveness, agility and collaboration

We take a collaborative and agile approach to enforcement, working closely with our Market Oversight function and internal teams to identify risks early, consider enforcement options from the start, set clear expectations, and shape responses. This allows us to act swiftly and use our enforcement powers when other interventions have failed to deliver effective outcomes.

We also work closely with our partners and external stakeholders to share intelligence, drive compliance, and coordinate responses across the pensions sector. This includes leading the Pension Scams Action Group and working closely with the Pension Protection Fund. Where issues fall outside our regulatory remit or overlap with others, we refer or coordinate with the appropriate bodies where legal gateways exist to secure the best results.

Our collaborative approach to tackling serious economic crime aligns with the Home Office’s Fraud Strategy.

3. Decisive action addressing non-compliance, regulatory breaches and economic crime

We act decisively in cases of serious harm that pose high risks to members or undermine trust in the pensions system. Where we consider there is, or is likely to be, an immediate risk to members or scheme assets, we will move quickly to use our powers. To do this, we rely on a special procedure.

Our approach is targeted and proportionate, prioritising cases that align with our strategic priorities. We apply clear thresholds, a defined risk appetite, and streamlined processes to ensure consistent, effective action.

When we uncover or suspect serious economic crime, we act quickly with our law enforcement partners to escalate these cases and coordinate an appropriate response where other agencies are better placed to act. We also coordinate with them to ensure victims of crime receive support throughout the process.

4. Enhanced transparency to influence behaviour, raise standards, build trust and support a safer pensions system

We want the industry and members to understand our expectations on what good conduct looks like, the risks they face, and how we respond. Transparency builds trust, raises standards, and contributes to a more effective pensions system.

We publish enforcement outcomes to highlight risks, clarify our expectations, and drive improved compliance and behaviours. We also share relevant information with our partners and stakeholders to support a coordinated response to risks and harms.

Where appropriate, we inform affected individuals, clearly explain our decisions, and remain as transparent as legal and confidentiality constraints allow. This approach helps ensure that our aims and expectations are understood, and that we are accountable for our decisions.

5. Data-driven enforcement delivering value and better outcomes

We use data and technology to support our work and make better decisions.

By investing in digital and data tools, we can detect trends, respond quickly, reduce regulatory burden, and focus our efforts with greater precision. Data also helps us to evaluate outcomes and continuously refine our approach, ensuring our enforcement is effective, efficient, and focused on delivering value for members.

We will continue to strengthen our use of data, analytics and digital capability to target enforcement activity where it delivers the greatest impact. This includes using data to identify emerging and evolving risks, prioritise cases, and support faster, more consistent decision‑making across the enforcement lifecycle.

Where appropriate, we will automate and streamline key processes, improve information management and sharing, and enhance our analytical capability to reduce duplication and enable timely, proportionate and outcome‑focused enforcement action, supported by a robust end‑to‑end case management capability.

Our approach

TPR’s approach is guided by our statutory objectives and the principles of good regulation, as set out in the Legislative and Regulatory Reform Act 2006 and the Regulators’ Code. We aim to be:

proportionate – our actions are appropriate to the risk and harm posed
accountable – we explain our decisions and accept scrutiny
consistent – we apply our approach fairly and reliably
transparent – we explain what we do and why we do it
targeted – we focus our efforts where they are needed and deliver the greatest impact

We use our enforcement powers across defined benefit and defined contribution schemes. We also ensure that employers comply with their automatic enrolment duties. Some of our powers can only be exercised by our committee, the Determinations Panel, which makes its decisions independently from other parts of the organisation. These powers are known as ‘reserved powers’. These include the power to prohibit a person from being a pension scheme trustee and our anti-avoidance powers, among other measures.

In some circumstances, we may decide not to initiate or continue enforcement action as part of a settlement agreement. When considering a proposed settlement, we carefully weigh the potential outcome against what could be achieved through enforcement.

To learn more about how we approach settlement negotiations and what we expect from those who submit proposals, please refer to our settlement policy.

In every case, we act early where we can, take a risk-based, outcome-focused approach, and target deterrent action where it counts - focusing on the greatest risks and harms to members.

Serious economic crime

This strategy covers both regulatory and criminal enforcement, recognising that certain types of misconduct may require action under criminal law.

Where serious economic crime is suspected, we act within our remit and capabilities, focus on investigations that align with our risk appetite and strategic objectives, and deliver meaningful impact for members.

Our approach is collaborative and targeted. We work closely with our law enforcement partners to coordinate investigations and share intelligence. We will prosecute in appropriate cases for breaches of pensions legislation. Where cases fall outside our capabilities, we refer or support partner agencies to ensure the right body takes the lead. In all cases, we seek to protect members and ensure victims receive appropriate support.

Offences that are considered ‘serious economic crime’ include fraud, money laundering, and other forms of financial crime that fall outside pensions law and may involve:

high complexity or harm
significant public, political, or media interest
international or multi-jurisdictional elements
emerging threats or vulnerabilities
links to organised crime
obscured intelligence
cases best handled by other law enforcement agencies

Enforcement toolkit

We use a range of regulatory tools to help us protect members, raise standards across the pensions system, respond proportionately to the nature and severity of an issue, and deliver positive outcomes.

Our toolkit includes both statutory powers and other regulatory measures, allowing us to identify and address risks early, often through guidance or supervisory engagement before they pose a serious threat to members. However, when cooperation fails, there is repeated non-compliance, or serious harm occurs, we escalate to stronger actions to protect members. These include directing actions, imposing conditions, issuing fines, appointing a trustee or prohibiting a person from being a trustee, and pursuing prosecutions, among other measures.

We take a strategic, evidence-based approach, choosing the most effective tool for each case based on the risks and harms involved and the outcomes we are seeking. Our approach is pragmatic, and we will consider alternative options where they offer the most effective result.

Read more about our enforcement powers, policies and procedures.

How we decide to act

Our enforcement work is informed by a range of sources, including:

our own monitoring, intelligence, and supervisory activity
reports from schemes and employers
whistleblowers
complaints and enquiries
other regulators and public bodies
publicly available information
self-reporting by those we regulate

We assess this information against wider risk and harm factors to decide if enforcement is needed. We apply our resources where they are needed most, including to new and evolving risks. Our enforcement activity is guided by our corporate priorities and through our support and collaboration with our Market Oversight teams.

We also receive third party applications which we are required by statute to pass to the Determinations Panel without any assessment of whether enforcement is needed.

We prioritise enforcement activity by assessing three key factors: impact, scale, and complexity, and evaluate the level of significance for each.

Impact

This focuses on the potential or actual harm caused, including the:

severity of detriment to members (financial and/or non-financial loss)
risk to market integrity or member confidence
opportunity to set a precedent or drive behavioural change

High impact case scenario: trustee misconduct that undermines member confidence and exposes them to financial loss.

Scale

This considers the breadth of the issue, such as the:

number of members affected
potential number of members, schemes, and employers affected or involved
size of the scheme or employer involved
potential systemic or contagion risk

High scale case scenario: a breach affecting thousands of members across multiple schemes, even if the underlying issue is straightforward.

Complexity

This refers to the nature and intricacy of the issue, including the:

legal, technical, or operational challenges involved
number of parties or jurisdictions concerned
level of investigation or specialist expertise required

High complexity case scenario: cross-border pension fraud with multiple actors and unclear legal responsibilities.

After assessing each factor, we choose the most appropriate response. We don’t follow a rigid formula, but our decisions are guided by core principles. This keeps our actions proportionate, well-justified, and focused on delivering good outcomes for members.

High impact or scale cases will generally be prioritised, even if they are low complexity.
High complexity cases will be pursued where they support our strategic objectives and offer a clear opportunity to deliver meaningful results for pension schemes, members, and the wider system. In some cases, we will also work closely with partners to coordinate our response or refer the matter to another organisation better placed to take action.
Low scale and low impact cases are less likely to result in formal enforcement action unless they form part of a broader pattern or present a risk of escalation. However, we may still address them through other regulatory responses. This includes targeted communications, guidance, or compliance-led enforcement, particularly where early intervention can prevent escalation or support wider compliance.

Outcomes

Enforcement is not just about holding parties to account. Where possible, it is also about putting things right. Where harm has occurred, we will look to use our powers to help restore losses, correct breaches, and ensure members receive the benefits they are entitled to.

Our enforcement activity aims to achieve one or more of four outcomes: prevention, reparation, accountability, and member confidence.

Together, these outcomes help us focus our efforts and measure the effectiveness and results of our enforcement activity.

Prevention

We aim to stop harm before it happens by:

acting early to prevent breaches of pensions law or duties
making sure appropriate funding is in place for schemes
using our powers and working with our partners to disrupt poor behaviour or criminal activity
working with schemes and employers to raise standards and influence behaviour to avoid future problems
raising awareness of risks and educating the industry to avoid recurring issues
collaborating with our key partners where a coordinated response is required

Reparation

When harm has already happened, we act to put things right by:

making sure schemes and employers correct any breaches of pensions law and meet their legal duties
restoring losses or detriment to schemes and members
making sure appropriate financial support is in place for schemes

Accountability

We hold people to account when their actions cause harm or fall short of the standards we expect by:

taking action against those responsible for breaches or misconduct
removing and replacing trustees who fail to meet required standards and, where appropriate, prohibiting them from acting again
facilitating compliance with regulations and using appropriate tools to drive impactful deterrence
promoting an industry culture where good member outcomes come first

Member confidence

We want members to trust that the pensions system works in their interests by:

taking action that protects the integrity of the market
working closely with industry and our partners to respond to risks, reduce regulatory burden, and deliver good outcomes for members
using our networks and partnerships to share information where gateways exist, coordinating responses, and improving enforcement outcomes

Publishing and communicating our enforcement outcomes

We publish certain enforcement outcomes to:

promote transparency
clarify our expectations
explain our actions
drive improved compliance and behaviours
flag emerging risks and trends
share lessons and help the industry to stay alert and responsive

Our communications highlight good practice, the impact of enforcement, and the consequences of falling short.

We recognise the importance of publishing enforcement results and continually review how we engage with the industry and members to make sure our messages are clear, accessible, and drive meaningful change.

While we aim to share as much as possible, some details may be withheld for legal or confidentiality reasons. In such cases, we try to provide enough context to maintain understanding and trust.

Find out more about how we publish enforcement activity and what activity we have published.