Small and lost pots
FOI reference - FOI-453
Date - 2 February 2026
Request
"I’m interested in finding out about small and lost pots across the UK. I would like to know the following:
- The number of pension schemes failing to keep customer records up to date for the 12 months to 31st December 2025. If possible I would like this information for the last five years.
- The number of pension schemes fined for failing to keep customer records up to date for the 12 months to 31st December 2025. If possible I would like this information for the last five years.
If it is not possible to provide information for the last five years, then please provide information for the last three years."
Clarification to your request
To help us provide the correct information for the first part of your request, we need a bit more clarity. Schemes are required to carry out two types of data assessments relating to member data quality. These are the data assessments that schemes are required to undertake:
We can report either:
- the number of schemes completing one or both of these assessments, or
- the number of schemes meeting a particular score threshold.
Could you confirm whether one or both of these would satisfy your request for information on 'schemes failing to keep customer records up to date'? If so, please specify what score threshold you would like us to use.
"I would like to know the number of schemes completing one assessment and the number of schemes completing both assessments please"
Response
I confirm that we hold the information you have requested.
The table below sets out the number of pension schemes failing to keep customer records up to date (see TPR’s guidance on assessing member data quality) for the years requested, split into:
- Occupational defined contribution (DC) non-micro schemes and Occupational defined benefit (DB) schemes
- Occupational DC micro schemes
DC micro schemes are subject to returning their scheme return once every three years, and are therefore shown in two non-overlapping three-year groups.
Table 1: DB schemes and non-micro DC schemes
| Year ending 31 December | Number of schemes assessed | Number of schemes completing one assessment | Number of schemes completing both assessments | ||
|---|---|---|---|---|---|
| 2020 | 6734 | 957 | 2651 | ||
| 2021 | 6522 | 934 | 2494 | ||
| 2022 | 6278 | 915 | 2135 | ||
| 2023 | 6100 | 906 | 2301 | ||
| 2024 | 5903 | 889 | 2289 | ||
| 2025 | 5686 | 821 | 2709 | ||
Table 2: Micro DC schemes (3-year groups)
| Period (year ending 31 December) | Number of schemes assessed | Number of schemes completing one assessment | Number of schemes completing both assessments | ||
|---|---|---|---|---|---|
| 2023 to 2025 | 853 | 30 | 181 | ||
| 2020 to 2022 | 1173 | 51 | 275 | ||
We can confirm that no scheme fines were issued for failures to keep customer records up to date during the periods covered by your request. Such failures fall under Pensions Act 1995 S10 (breach of Pensions Act 2004 S62), which gives TPR a civil penalty power for failing to maintain registrable information, with a maximum of £5,000 for individuals and £50,000 in any other case.
You should note the following when interpreting this information:
- All figures have been rounded to the nearest 10. This may mean that the number of schemes may not be an exact count.
- This source information is provided directly by pension schemes in response to the mandatory annual scheme return for non-micro schemes, and every three years for micro schemes. Data is not weighted or imputed to account for non-response to the scheme return.
- Schemes included are either DC, or DB and Hybrid (dual section and mixed benefit) occupational schemes. Schemes which are gone-away, not registrable, wound-up and schemes with less than two members have been excluded.
- For DC schemes, relevant small self-administered schemes and executive pension plans (RSS/EPP) are not required to provide scores. RSS/EPPs, and schemes where RSS/EPP status is unknown, have been excluded from the figures.
- This information disclosed reflects the data held for all DB and Hybrid schemes on 1 April for the years 2021, 2022, 2023, 2024 and 2025, and on 31 December for DC schemes.
- The methodology for DC micro schemes differs from other occupational schemes. This is because DC micro schemes report to TPR via their scheme return every three years.
Duty to provide advice and assistance
Section 16 of the FoIA imposes a duty to provide advice and assistance.
For further clarity, we ask schemes to provide us with ‘common’ and ‘scheme-specific’ scores in the mandatory scheme return.
Schemes are legally required to operate adequate internal controls. Our code of practice4 requires them specifically to ‘assess the need for a data review’ annually and our guidance indicates that most schemes should be doing an annual review, however not doing so is not a breach of legislation in and of itself.