Corporate Strategy consultation response
Published: 14 July 2026
Introduction
In May 2026, we published our draft corporate strategy for consultation, setting out a new strategic framework to guide our work over the next five years. The consultation was open for four weeks and invited feedback on the following questions:
- Does our vision of people having a sustainable income in retirement set the right long-term ambition for the pensions system? Could it be strengthened?
- Are the trends we identify – including consolidation, scale, technology, digitalisation and artificial intelligence – the main forces that will shape the system over the next five years? What’s most important? Is anything missing?
- Where could The Pensions Regulator’s (TPR) role be more active, or targeted, to maximise saver outcomes and support a resilient and sustainable market?
In total, 34 external stakeholders responded to the consultation, with respondents representing a broad cross-section of the pensions ecosystem or consumer groups. We have carefully reviewed all the responses, and stakeholders’ views have informed our approach to finalising the strategy.
During the consultation period, we convened two stakeholder roundtables, and we factored the views from these discussions into the overall analysis of responses.
We are grateful to all the stakeholders who have taken the time to engage with the process.
What respondents said – overview
Stakeholders expressed strong overall support for the direction set out in the draft strategy. There was widespread endorsement of the proposed vision and the shift towards a more system-wide and outcome-focused approach to regulation.
Respondents also provided constructive feedback on areas where the strategy could be strengthened or clarified. Several consistent themes emerged. These themes are set out below, together with our response.
In addition to the themes below, several stakeholders asked for more emphasis on other initiatives throughout the strategy. These included, for example, our work on growth, climate and value for money. We agree these are hugely important topics. Our approach and expectations to these topics will be made clear in the deliverables outlined in our latest Corporate Plan published alongside this strategy.
Thematic feedback and our response
Vision and adequacy
Stakeholders broadly supported the vision and our focus on system-wide outcomes. However, several respondents highlighted that the concept of sustainability could be interpreted narrowly only as an income that lasts through later life. They suggested we should explicitly refer to adequacy alongside sustainability.
We have carefully considered this feedback but have retained the existing vision. The vision is grounded in our statutory role and levers – system design and governance. We have strengthened the accompanying narrative to clarify that when we describe a sustainable income in retirement we mean: one that lasts through later life, within a system that is stable and resilient, supporting a good standard of living. We recognise that adequacy and sustainability are connected and are committed to helping government understand the circumstances of pension scheme members and the system. However, what constitutes an adequate income depends on wider social factors, including housing, care, and workforce policies, which sit outside our remit.
Regulatory approach and joint working
Stakeholders placed strong emphasis on the importance of regulatory coordination, particularly between TPR and the Financial Conduct Authority. Many respondents noted that while the draft strategy referenced joint working, the importance of cross-regulatory collaboration could be more prominently reflected, given the interconnected nature of many of the challenges facing the pensions system.
In response, we have added further references to joint working within the strategy, including clearer articulation of the role of collaboration in delivering system-wide outcomes. We have also added specific reference to the Prudential Regulation Authority and the Pension Protection Fund as key partners.
Decumulation and retirement outcomes
Decumulation was a prominent area of stakeholder focus, with many respondents highlighting its importance in determining overall retirement outcomes. Stakeholders noted that the transition from accumulation to retirement presents significant risks for savers if not well managed and suggested that we could play a more active role in shaping good outcomes in this space.
We agree that decumulation is the most significant system-wide challenge. In response we have emphasised the scale of the challenge and our focus, as well as the importance of innovation and new services in meeting this challenge.
Defined benefit endgame planning
Respondents noted the increasing complexity surrounding defined benefit endgame planning, particularly as schemes consider a wider range of options including buy-out, run-on and alternative structures. Some stakeholders felt that the draft strategy could more clearly articulate our expectations and role in supporting trustees through these decisions.
In response, we have more clearly acknowledged the complexity facing trustees and the importance of robust governance and decision-making in this area. We have also included further reference to public service schemes. Our specific expectations of schemes in end-game planning have already been made clear within our DB Options and Models guidance.
Governance and trusteeship
Governance and trusteeship were identified as key enablers of good outcomes, with stakeholders highlighting the increasing scale and complexity of schemes and the implications this has for trustee capability and oversight. Respondents also emphasised the importance of reflecting the voice of members and considering the broader ecosystem of advisers and service providers.
In response, we have reinforced the emphasis on several of the sub-themes raised by stakeholders, including complexity of the trustee role, trustee independence, and member voice.
Technology and artificial intelligence
Stakeholders highlighted both the opportunities and risks associated with technology and artificial intelligence (AI), noting the potential for innovation to drive improved efficiency and outcomes, alongside risks relating to governance, oversight and digital exclusion.
In response, we have strengthened the link between AI-based innovation and governance within the strategy, as it is critical that technological developments are framed within a context of appropriate safeguards and accountability.
Next steps
The corporate strategy will provide the strategic framework for our work over the next five years, setting the long-term direction and priorities for the organisation.
The strategy is complemented by our new Corporate Plan, which translates our strategic direction into specific deliverables and activities for 2026/27.
As the strategy is implemented, we will continue to monitor developments across the pensions landscape and remain responsive to emerging risks, opportunities and stakeholder insight. This will include using our focus on outcomes to inform ongoing strategic prioritisation of our work and ensuring that resources are directed where they can have the greatest impact in pursuit of the outcomes we have defined.
We will also seek to maintain an active dialogue with stakeholders throughout the lifecycle of the strategy, building on the engagement undertaken during the consultation.
Appendix: Consultation respondents and roundtable attendees
- ABI
- Age UK
- AMNT
- Aon
- APPT (Association of Professional Pension Trustees)
- Aptia Group
- Ario Advisory
- Association of Consulting Actuaries (ACA)
- Aviva
- BESTrustees
- Carbon Tracker
- DWP
- FCA
- Financial Inclusion and Markets Centre (FIMC)
- Fossil Free West Yorkshire
- Hymans Robertson
- Institutional Investors Group on Climate Change (IIGCC)
- Investors for Purpose
- Law Debenture Pensions
- Lord Mayor / City of London
- LPPA
- MaPS
- Mercer
- NEST Corporation
- New Capital Consensus
- PASA
- Pension Protection Fund (PPF)
- Pensions UK
- People’s Partnership / People’s Pension
- PMI
- Royal London
- Scottish Widows
- ShareAction
- Standard Life
- The Pensions Ombudsman
- Thrive
- TISA
- TUC
- UK Private Capital
- UKSIF
- UNISON
- USS
- West Yorkshire Pension Fund
- Which?