Our new approach to enforcement: consultation document

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Who this consultation is for

This consultation is intended for anyone with an interest in how we approach and use our enforcement powers to protect savers, uphold standards across the workplace pensions system, and meet our wider statutory objectives.

We particularly welcome responses from:

• trustees and scheme managers of defined benefit and defined contribution pension schemes
• employers subject to automatic enrolment duties
• industry bodies and professional advisers, including legal, actuarial, covenant, and governance experts
• policy partners, government departments, and other regulators
• consumer and saver representative groups
• stakeholders involved in fraud prevention, compliance, and enforcement

Consultation context

The pensions landscape is changing, and so must we. While our current approach has delivered important enforcement outcomes, we recognise the need to adapt.

Our new enforcement strategy reflects an important shift in how we regulate. It introduces a more focused, agile, and outcomes-driven model, aligned with our statutory objectives, our corporate priorities, and our shift toward a more prudential style of regulation. It marks a deliberate move toward smarter, collaborative, and risk-based interventions that deliver real-world results.

We are committed to protecting savers and safeguarding the integrity of workplace pensions. The needs of savers, and the risks they face, are changing. The pensions landscape is complex, expectations are high, and the consequences of failure significant.

In response to these challenges, our wider transformation reorients our approach towards risk-based regulation and our new enforcement strategy is a key step in implementing that vision. It reflects our commitment to evolving our approach so we can act earlier, respond more effectively to serious risks, and deliver better outcomes for savers. We will use the full range of regulatory tools at our disposal, to prevent harm and bring about good outcomes – ranging from communications and direct engagement with schemes to taking enforcement action. We want to act early to prevent problems from developing in the first place but will not hesitate to take stronger action where necessary.

We are seeking views from across the industry to test the clarity of our approach to ensure it is proportionate, transparent, and effective. Your feedback will play a vital role in refining the strategy, helping us to strengthen workplace pensions for the future.

We welcome your insights and thank you for your continued engagement in helping us build a pensions system that works in the best interests of savers.

We are seeking feedback to ensure our new enforcement strategy is:

• clear and accessible
• proportionate and transparent in how we approach, prioritise, and use our powers to enforce
• effective in delivering good outcomes for savers
• visible and free from regulatory gaps

What's different about this strategy

Our proposed strategy introduces several changes designed to make enforcement smarter, more strategic, and more impactful.

Putting saver outcomes first

Our focus will shift from monitoring outputs to delivering real-world outcomes, such as preventing harm, securing redress, and building saver confidence. This change encourages meaningful, long-term improvements and increases trust in our enforcement activity.

Setting clear enforcement priorities

We will focus our enforcement efforts on the issues that matter most and those that pose the greatest risk to savers and the pensions system. By setting clear, central priorities and applying them consistently, we can make better use of our resources and take action where it will have the greatest impact and value. 

Targeted enforcement

We will take a proportionate, risk-based approach that concentrates resources on the most serious harm to savers. This supports our broader shift toward a prudential regulatory model and contributes to long-term economic resilience in the pensions system.

Acting earlier to prevent harm

We will consider enforcement earlier to stop problems before they escalate. This means closer integration between our Enforcement and Market Oversight teams and enables us to act faster, set clearer expectations, and engage in early interventions to prevent harm and stop issues before they grow.

Working together to solve problems

We will promote cross-functional working and deepen collaboration with our external partners and stakeholders. This will help us respond more effectively to complex or emerging risks and deliver joined-up enforcement outcomes that deliver impact and value.

Building flexible and skilled teams

We are investing in a more resilient and adaptable workforce, training and deploying staff more flexibly across different types of cases to improve efficiency and ensure the right expertise is available where it’s needed most.

Using data to make smarter decisions

We will use data and digital tools to spot trends, guide decisions, and track results. This supports smarter, evidence-based enforcement and helps us learn and adapt over time, increasing efficiency and reducing regulatory burden.

Being open about what we do

We will optimise how we publish enforcement outcomes and communicate expectations. Clear, timely messaging will help us to continue building trust, drive behavioural change, and improve standards and accountability across the industry.

Together, these changes will help us deliver the right action, at the right time, to achieve the right outcome: protecting savers, raising standards and compliance, and supporting a pensions system that works in the best interests of savers.

Future policy review and consultation

We expect that the adoption of this strategy will require us to revisit our wider suite of enforcement policies and procedures, including areas where there may be overlap, opportunities for consolidation, or a need for updates. This may include further consultation on specific policies to ensure they remain aligned with our new strategic approach.

Our current Enforcement strategy, policies and procedures remain in force and continue to guide our work. These documents set out our current approach to investigations and the use of our broader enforcement powers.

Government consultation principles

This consultation paper follows the government consultation principles.

The key principles state that consultations should:

• be clear and concise
• have a purpose
• be informative
• be only part of a process of engagement
• last for a proportionate amount of time
• be targeted
• take account of the groups being consulted
• be agreed before publication
• facilitate scrutiny
• be responded to in a timely fashion
• not be launched during local or national election periods

Responding to the consultation 

Stakeholders are encouraged to read the strategy in full before responding to the consultation.

We welcome responses from all stakeholders with an interest in our enforcement strategy and its impact on the pensions system.

When responding, you should consider the consultation questions and provide your views on any aspect of the draft enforcement strategy. You do not need to answer every question, and we invite partial responses.

You can also respond to the parts that are most relevant to your experience or interests and add any other comments you may wish to provide.

We are conducting this consultation in a digital format and encourage you, where possible, to use our online survey (opens in new tab) to respond to the consultation.

If you are unable to use this format, please use the options below to respond. Note that we are not providing a separate form to complete (other than the online survey).

Please submit your response by midnight 11 November 2025.

You can email your response to: enforcementstrategy@tpr.gov.uk.

Or send it by post to:

Ross Cunningham
The Pensions Regulator
Telecom House
125-135 Preston Road
Brighton
BN1 6AF

If you have any questions about the consultation process, please contact Ross Cunningham at ross.cunningham@tpr.gov.uk.

When responding, please let us know:

• whether you are replying as an individual or on behalf of an organisation
• if you are responding on behalf of an organisation, whether your answers reflect your personal views or the official views of the organisation

You should also provide:

• your name
• organisation name and type (if applicable)
• job title
• email address
• telephone number
• confirmation of whether we can list you or your organisation as a respondent

If you want your response to remain confidential (in part or in whole), you should specify this and let us know why.   

We will review all responses carefully and publish our response to the feedback received.

Consultation questions

• Do you agree with the overall direction of the proposed enforcement strategy?
• Is our approach sufficiently transparent and accountable?
• Does the strategy clearly explain how enforcement decisions will be made and prioritised from a strategic perspective?
• Are there any areas where the proposed strategy could be clearer or more accessible?
• How well do you feel the strategy aligns with our broader shift toward a more prudential, risk-based regulatory model?
• Are there any risks or unintended consequences arising from our new strategy you think we should consider?
• Are there additional safeguards or clarifications you would like to see?
• How can we best measure the success of this strategy in delivering real-world outcomes for savers?
• We expect to review and update our wider suite of enforcement policies in light of this strategy. Are there any specific areas or policies you believe should be prioritised for review?
• Do you have any other comments, suggestions, or concerns about the draft enforcement strategy?

Appendix: draft enforcement strategy and related policies

Our enforcement strategy sets out our proposed approach to enforcement, including:

• our mission and strategic objectives
• how we prioritise enforcement activity
• the outcomes we aim to achieve
• our enforcement toolkit and decision-making framework
• our approach to serious economic crime
• how we communicate enforcement outcome

Our mission

We deliver effective and efficient enforcement that:

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

Our enforcement strategy sets out how we deliver our mission, 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 savers.

Our enforcement strategy is focused, agile, and outcomes-driven. It reflects our wider regulatory transformation, addresses shifting risks in the pensions landscape, and keeps real-world impact at its core.

We aim not only to protect savers and uphold standards, but to support a well-functioning, transparent pensions sector that contributes to long-term economic growth. A smarter, more proportionate enforcement model reduces unnecessary regulatory burden, encourages innovation, and strengthens market confidence, creating the conditions for a thriving pensions system that supports the UK’s broader economic resilience.

Enforcement strategic objectives

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

Targeted enforcement that tackles the key risks and harms to savers with the greatest impact

We target enforcement where the risk to savers 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 savers, particularly those who are vulnerable or at greater risk. This includes lower-income workers and savers 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. 

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. 

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

We act decisively in cases of serious harm that pose high risks to savers or undermine trust in the pensions system. Where we consider there is, or is likely to be, an immediate risk to savers 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 work closely with our partners to ensure victims of crime receive support throughout the process. 

Enhanced transparency, building trust, and supporting a safer pensions system

We want the industry and savers 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.

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 savers. 

Our approach

The Pensions Regulator (TPR) regulates workplace pensions in the UK. Our 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 (DP), 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, amongst others.

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 savers.

Serious economic crime

This strategy covers both regulatory and criminal enforcement, recognising that certain types of misconduct may warrant a criminal response.

Offences that are considered ‘serious economic crime’ include fraud, money laundering, and other forms of financial crime that fall outside pensions law. These offences 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 savers, raise standards across the pensions system, act proportionately and effectively based on the nature and severity of the issue, and deliver effective outcomes.

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

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 that we are required by statute to pass to the DP 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 savers (financial and/or non-financial loss)
• risk to market integrity or saver confidence
• opportunity to set a precedent or drive behavioural change

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

Scale

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

• number of savers affected
• potential number of savers, 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 savers 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 savers.

• 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, savers, 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 complexity, 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

Our enforcement activity aims to achieve one or more of four outcomes: prevention, reparation, accountability, and saver 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 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 savers
• 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 saver outcomes come first

Saver confidence

We want savers 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 savers
• 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 savers 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.