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Corporate Plan 2019 - 2022

Foreword

Charles Counsell Our 2019 - 2022 Corporate Plan comes at a time of continuing change, both in the pensions landscape and in the way that we work. The final increase in automatic enrolment (AE) contributions to 8%, the authorisation of master trusts, and the Department for Work and Pensions (DWP) ongoing work resulting from the defined benefit (DB) white paper all create new and diverse challenges for pension schemes, employers and us all at The Pensions Regulator (TPR).

Internally, we continue to develop clearer, quicker and tougher interventions through our TPR Future Programme. This programme, which we launched three years ago, covers cultural, structural and procedural aspects of our regulation, and is informed by our successful AE operating model.

New initiatives that set clear expectations

Throughout 2019 - 2020 we will apply new regulatory initiatives to hundreds more schemes to influence their behaviours and improve outcomes for savers. We hold those responsible for looking after retirement savings to high standards, and we know that stakeholders, schemes, employers and advisers are embracing our clearer, quicker, tougher regime.

From complex DB schemes and the master trusts we now authorise, to smaller schemes and new employers receiving targeted communications from us about their duties, our focus is on clarity of expectations. At the larger end of the market, our new supervision team is establishing one-to-one relationships with schemes of strategic importance upon whom millions of savers rely. And our new range of regulatory tools and techniques – including high-volume targeted communications and broader thematic work – means we can talk to more trustees about more aspects of their duties.

Extending regulatory grip

Our regulatory grip extends to far more schemes than in the past, including smaller schemes with comparatively lower governance standards. We will engage with these schemes if they cause us concern, and our enforcement team will carry out full investigations into those who wilfully or persistently flout their duties.

Looking further forward, we are developing a consolidation plan for defined contribution (DC) schemes that have difficulties meeting the standards we expect. As part of this, our recently published winding-up guidance will assist trustees of DC schemes in understanding the key steps they must undertake as part of the wind-up process if they conclude that their members would be better off in a different pension arrangement.

Using a broader range of powers

Over the past year we’ve used a broader range of our powers to deter and punish those who persistently fail to comply. This included our first prosecution for fraud, our first custodial sentence, and the courts handing down the largest ever fine that followed a TPR prosecution. Our actions saw Southern Water agree to pay £50 million more into its pension scheme under a shortened recovery plan, and our scheme funding team succeeded in making an employer effectively treble its deficit repair contributions and drastically shorten its recovery plan within just a few months of engagement.

In addition, last year we undertook our first prosecution of an accountant for falsely claiming an employer had met its AE duties. We also secured a large fine against a recruitment firm as well as suspended custodial sentences for staff who plotted to illegally opt out people from their workplace pension.

These examples demonstrate that ‘clearer, quicker, tougher’ is not just a slogan, but a real reflection of the way we are holding to account those who fail to do the right thing by their scheme members or employees.

Following on from the White Paper proposals for strengthening TPR’s scheme funding powers, the government published the response to its consultation on A Stronger Pensions Regulator in February. This set out plans for new powers for TPR on information gathering, and new penalties to tackle/deter reckless behaviour. It also set out proposals for new notifiable events and for a Declaration of Intent to encourage employers to collaborate more closely with trustees when corporate decision making could adversely affect the pension scheme.

We are drafting a new DB funding code of practice which will explain clearer standards to help trustees and employers to agree good funding outcomes for their schemes and better equip us to take enforcement action. We will be engaging actively with our stakeholders and other regulators to ensure the revised code is based on expert input, has contributions from industry and provides practical guidance on long-term funding.

Ensuring good governance

Communications-led initiatives such as the Trustee toolkit and our 21stCentury Trustee programme have helped to set clearer expectations of what we consider to be good governance. Phase two of the 21st Century Trustee programme will focus on the make-up of trustee boards and the impact of industry-developed competency standards and accreditation for professional trustees.

Our record-keeping and data quality initiatives will be vital for the successful introduction of the pensions dashboard, and we will work with the DWP, the Money and Pensions Service, the Financial Conduct Authority (FCA) and the dashboard delivery group to develop the regulatory framework for effective consumer-facing dashboards.

Protecting pension savers

We have already made a lot of progress in protecting the 10 million people either newly saving or saving more thanks to the success of AE. With the increase in contributions, it is more crucial than ever that savers have confidence that their pensions are safe. Our authorisation programme ensures master trusts are run by fit and proper people and have the right systems, processes, plans and finances in place. And where fraudsters have sought to undermine that confidence through scamming people out of their savings, we will continue to lead criminal investigations that bring them to justice.

We are aware of the increased pressures placed on our workforce and are proud of the way the TPR teams have risen to the significant challenges asked of them this year with dedication and enthusiasm. Our transformation as a regulator has meant significant changes to what our teams do, as well as how they do it. We will remain committed to the individual personal development of each member of the TPR teams to ensure we can do the best job that we can do on behalf of pension savers.

This year’s Corporate Plan will ensure that we build on the progress made over the last couple of years and that we continue to make workplace pensions work while providing value for money for our regulated community. We will maintain the momentum from these changes in our regulatory approach to ensure that we are clear in our expectations of schemes and trustees, quick to spot and act on issues emerging and tough in our pursuit of those who do not fulfil their duties and obligations.

Charles Counsell's signature

Charles Counsell, Chief Executive

Mark Boyle

Mark Boyle, Chairman

About us

We are the public body that protects workplace pensions in the UK. We work with employers and those running pensions so that people can save safely for their retirement.

You can read more here about the objectives that government has given us, our approach to regulation and the values we hold that enable us to realise our vision of being a strong, agile, fair and efficient regulator.

The pensions and risk landscape

In developing this Corporate Plan we have considered the core regulatory risks that pose a significant threat to the achievement of our regulatory outcomes. These are:

  • A failure or unmanaged exit of a trust-based scheme, providers or regulated entities.
  • Excessive numbers of individuals deciding to opt out or stop saving into pensions.
  • DB schemes not being funded to a level to assure that future member benefits will be paid in full.
  • Employers being required to fund pension scheme deficits at the expense of investing in the growth of their business.
  • Pension schemes or their members becoming victims of fraud.
  • Poor governance or trustee decision-making resulting in poor member outcomes or loss of benefits.
  • Poor administration resulting in poor member outcomes or loss of benefits.
  • Employers seeking to avoid their responsibilities to the pension scheme.
  • Savers suffering a loss due to making poor decisions about their pension funds because they were misinformed or uninformed.
  • Employers not complying with their duties to provide pensions to their staff.

Our organisational priorities for the next year are based on our analysis of these risks and the likely impact of broader economic and market influences.

Economic and market outlook

The performance of economic and financial markets has a major impact on savers, whether directly on scheme funds or indirectly through their impact on employer support and affordability. Therefore, we will continue to prioritise work to understand and prepare for the implications of the UK’s exit from the European Union (EU), with a particular focus on the sectors or segments that are most exposed. This has the potential to affect the roll-out of this Corporate Plan, depending on the outcome.

The UK’s annual GDP growth for 2018 was 1.4%, the lowest since 2012. The consensus view among leading forecasters is that the economy will experience a similar level of performance this year. These forecasts, however, are made against a backdrop of continuing uncertainty. The global economy faces the risk of slowdown across the major economies of China, the United States and the EU. We recognise that developments in these areas may contribute to the volatility of the financial markets and affect the trading environment of employers and pension scheme sponsors.

Pension Trends

The key pension trends we are observing in the market at the moment are:

DC market maturing

AE has led to a significant rise in the number of employers offering their employees access to workplace pensions and, as a result, a huge increase in the number of memberships of workplace pensions. One short-term effect of this influx of new savers with no existing assets was a huge decrease in average assets per person. However, as we are now at the point where all pre-existing employers are subject to the requirement to offer a workplace pension, we expect to start to see the DC market mature. The effects we expect to see include:

  • an ongoing increase in total memberships arising from savers joining the workforce or changing employers
  • an increase in the number of small pots created while the market matures
  • stability in the number of active memberships as the number of savers joining the workforce matches those who are retiring
  • an increase in average assets during accumulation and at retirement

The effect of this is to further increase the significance of risk within the DC market, with a growing number of savers increasingly reliant on DC benefit payments. Therefore, the overall importance of the sector, including governance, administration and engagement, is also increasing. We will therefore place a particular emphasis on improving standards and ensuring savers have the information they need to make informed decisions.

Scheme consolidation

Total WPP across sector by year as at 1 January (excluding SSAS)

Graph showing total WPP across sector by year (exc SSAS) from 2013 - 2019As can be seen in the table above, the number of schemes in the market has been reducing year-on-year. Alongside this the total number of memberships has increased dramatically, leading to an increase in the concentration of savers. Statistics on transfers suggest that this concentration is, to some degree, driven by consolidation, with employers closing their standalone DC schemes and moving memberships, including existing assets, into master trusts. We welcome the trend towards consolidation in DC schemes, although we are mindful that it is not appropriate in all cases (for example, many DC schemes offer some level of enhanced benefit, such as guaranteed annuities).

There has been a less pronounced trend towards concentration among DB schemes, and what little there has been is difficult to attribute to market consolidation. It may simply be employers closing DB schemes and opening DC schemes. This view is supported by the fact that we have seen a bigger reduction in open schemes than we have in total schemes, and while employers are closing DB schemes they are not necessarily transferring out assets. However, the emergence of superfunds – also known as DB consolidators – suggests we can expect to see an increase in DB consolidation in future years.

We will be working with government on an effective regulatory regime for superfunds (in addition to effective implementation of master trust authorisation and supervision) to ensure that any consolidation is in the best interest of savers. We will also continue to hold all remaining trustees and managers, irrespective of scheme size and type, to the standards we expect.

Master trusts

The increased concentration of memberships outlined above has the potential to heighten the threat posed by the failure of a major scheme.

Master trust authorisation and supervision holds those running these schemes to high legislative standards. However, there is a risk that a master trust will fail to meet requirements and lack the means to wind up appropriately. This could result from a scheme that cannot find suitable managed exit arrangements, cannot afford to properly wind up and/or has trustees that do not act adequately to protect members.

To counter this we are overseeing the exit from the market of those master trusts that do not wish to, or fail to obtain, authorisation. Trustees of existing schemes must provide us with a detailed plan of how they will wind up the scheme and transfer out the assets. We then oversee trustees to ensure that they are sticking to that plan.

Member engagement

There has been a distinct change in the profile of memberships from DB to DC schemes and an increased use of default funds. This largely stems from DB scheme closures and the implementation of AE1. This, combined with the introduction of pension freedoms, provides savers with more control and autonomy over their pension arrangements.

1 It should be noted that, while active membership of DB has reduced significantly, total membership remains high (over 11 million), as do assets (£1.6 trillion).

This graph highlights the increasing scale of risk to members and the need for good trusteeship to ensure high standards and effective regulatory protections are in place.

As a result of this the risks members are bearing have increased. Savers may make poor decisions, potentially due to a lack of engagement, lack of knowledge, poor advice or misinformation, leaving them susceptible to inadequate retirement benefits and potentially scam activity. We will focus on increasing public awareness and disrupting scams as well as working with government agencies and industry to improve the quality of information that savers receive.

Trustees

One of the major risks to member outcomes that we have identified relates to poor governance of schemes and poor decision-making by trustees. There has been a general reduction in the number of schemes over the last five years, with one in seven schemes closing and the number of trustees therefore reducing.

Table B: Trustees by year and benefit type, excluding small self-administered schemes (SSAS) and executive pension plans (EPP).

Please note: there will be duplication in benefit structure figures as trustees may be linked to multiple types of scheme and so totals are not cumulative.

All Schemes 2015 2016 2017 2018 2019
Total Trustees 23,000 22,000 20,000 18,000 16,000
DB 12,000 12,000 11,000 10,000 10,000
DC 9,000 8,000 7,000 6,000 5,000
Hybrid 4,000 3,000 3,000 3,000 2,000

Excluding SSAS and EPP, approximately 16,000 trustees operate in the market. Of these, only 4% (approximately 670) 2 have identified themselves as professional trustees. However, while this number may seem very small, each professional trustee is likely to act for a number of schemes so the proportion of schemes being run by professional trustees will be much greater.

2 7,400 trustees identified themselves as lay trustees on the Scheme Return and the remaining 8,000 trustees in this population did not specify whether they were lay or professional trustees.

The high number of trustees, and in particular lay trustees, underlines the need to take action to raise governance standards across the board by ensuring that trustees are aware of their duties. We have been working through the 21st Century Trustee programme and the Professional Trustee Standards Working Group to achieve this.

Chart 2: Professional status of trustee boards by scheme benefit type

Schemes by the professional status of their trustee board
Graph showing schemes by the professional status of their trustee board

It is also important to note that, even excluding SSAS and EPP, nearly a quarter of schemes have fewer than 100 members. Trustees of smaller schemes are more likely to rely on service providers to support scheme management. This, in addition to the influence some providers have in the market, is why we are building a better understanding of risks by improving our understanding of, and engagement with the pension service providers.

Administration

TPR has a statutory objective to promote the good administration of occupational pension schemes. We have identified the potential for poor administration to result in bad outcomes for savers or loss of benefits as a significant risk. This is as a result of the behaviours we have observed in individual schemes and the dynamics of the administration market as a whole. While administration is of central importance for the delivery of timely and accurate pension benefits, our research consistently shows that administration is often viewed as a low priority for schemes. Even where trustees are taking action to address the quality of record keeping it is often limited to assessing the presence of data, rather than quality and timeliness.

There are around 1,600 administrators within the UK occupational pensions market, excluding SSAS and EPP schemes. Although some of these services are provided in-house, around half of schemes have their administration outsourced to third parties3.

3 c. 6700 of 13600 occupational schemes

Table A: Occupational scheme administrators, memberships and scheme counts by role subtype.

This data includes DB, DC, Hybrid and Public Service schemes and excludes SSAS, EPP and personal pension schemes.
Please be aware some administrators will offer multiple types of service and so totals are not cumulative.

  All Role Sub Type
In-house Third Party Insurer Administrator Unknown
Administrators 1,600 900 700 100 -
Memberships 45,553,000 18,339,000 26,221,000 1,832,000 75,000
Schemes 13,600 1,600 6,700 2,400 3,000

A group of 14 administration companies together administer approximately half of all occupational memberships.

The pension administration business typically runs at low margins, reducing the incentive and ability for providers to make significant investment in their administration technology. As a result, buy-outs, consolidation and provider changes are more likely to be complicated by legacy data and systems. One mitigating factor is the arrival of master trust authorisation. These schemes are required to meet specific duties and standards, which include robust administration processes and evidence of financial sustainability. Of the top 14 external administrators, eight are master trust providers.

Chart 3: Occupational membership coverage of the Top 14 administrators, compared to the rest of the administrator market.

Graph showing administrator coverage of members by benefit typeThe administration market is dominated by a small number of providers. We are, therefore, engaging with these providers to better understand the market and ensure higher standards of administration.

Because of its importance in contributing to good outcomes for savers we are monitoring the standards of record keeping via our scheme return, through which we collect information from schemes regarding the proportion of ‘common data’ they are holding. Common data includes basic contact details, so gaps in record keeping increase the risk that savers will not receive the benefits due to them.

Our analysis shows that schemes overall hold approximately 90% of the required common data, meaning some members are at risk of not receiving their benefits, so we will be prioritising the improvement of record keeping standards.

Our Priorities

The process of identifying and assessing the core regulatory risks in the landscape has enabled us to develop our priorities for the next three years. These build on the priorities set out in last year’s Corporate Plan.

The six priorities below reflect our current outlook for the next three years (2019 through to 2022). However, the specific activities we have outlined under each priority relate to the 2019-2020 financial year.

Building on the work developed by the TPR Future programme over the last year, we will be rolling out new regulatory initiatives on governance, administration, DB funding, and savers’ decision making. These cover the core regulatory risks we have prioritised against the current landscape and the way that we address them.

Through our new supervisory approach we are developing strong, two-way relationships of varying intensity with schemes that are the most strategically important to us. This will enable us to have a greater impact on the behaviour of trustees and employers. We are also working on a targeted supervision model where schemes will be supervised as and when is needed in response to potential risks or events.

We will engage with more schemes than ever before, informing trustees of the standards we expect and tackling risks early. This will start with us writing to trustees, reminding them of their obligations and directing particular activity, and will be followed by targeting those who continue to cause concern. Where we uncover entrenched non-compliance, we will undertake full investigations which may lead to enforcement action. We will refer to this in our early engagement messaging with schemes to encourage positive responses and to make our position and willingness to act clear.

Our regulatory grip will extend to even more savers as a result of master trust authorisation. By the end of the year every master trust that continues to operate will have proved that the scheme, its trustees and other key parties meet the legal requirements for authorisation. This will better protect the millions of members and billions of pounds in those schemes. We will continue to closely supervise master trusts that get authorisation, and make sure that those that don’t obtain authorisation because they don’t meet the standards leave the market in a controlled way.

Last year we published our joint strategy with the FCA where we recognised the importance of addressing the generally low levels of consumer understanding and engagement, and the potential for poor advice and pension scams. We will launch a joint review of the consumer pensions journey, which will examine how disclosures and information from pension schemes and providers combine with guidance and advice services to help consumers make well-informed decisions. We will also jointly focus on value for members

We will also work with the FCA and the Money and Pensions Service on DB to DC transfers to ensure that they work effectively for those who want to transfer, but enable savers to understand the risks involved and the options available to them. This is particularly important at points where schemes are distressed or employers are going through high profile changes. This work will build on the recommendations of the independent review into the communications and support provided to members of the British Steel Pension Scheme.

This year we are increasing our proactive work to drive up standards of governance and administration, especially among smaller schemes where some trustees are less engaged or lack the skills to achieve good outcomes for their members. We will focus on reducing the number of poorly run schemes by consulting on a range of proposals designed to improve governance standards and encouraging trustees who cannot meet them to consider transferring their members to better run, better value schemes.

Our strategy for regulating schemes that fall short of the governance and administration requirements includes:
  • developing a new governance code of practice
  • consulting on the future of trusteeship and trustee standards
  • regulating compliance with new trustee obligations resulting from the Competition and Markets Authority (CMA) investment consultants market investigation
  • focusing on the schemes that fall short of governance requirements

Accurate record-keeping is a cornerstone of good administration, contributing to good outcomes for savers and successful pensions dashboards for the future. However, many schemes continue to struggle with data processing and quality. We expect this to improve and will use thematic reviews and data from scheme returns to tailor our communications to the right audience, so trustees and administrators are in no doubt as to our expectations of them. There is evidence that administration is a particular issue among public service (PS) schemes (eg with late payment of scheme contributions or failure to provide annual benefit statements). A driver for this may be poor data. The 2018 PS Governance and Administration Survey highlighted that three-quarters of schemes that had undertaken a data review in the last year uncovered issues, with only 7% completing rectification work.

While the PS survey shows improvements between 2017 and 2018, respondents have highlighted significant barriers to future improvements, including the complexity of the scheme and lack of time and resources. We will focus on administration and data management among PS schemes and make sure we strike the right balance of support and education with using our powers where there is persistent failure to improve. Our recently published regulatory intervention report on Oxfordshire County Council Pension Fund shows how we have achieved this in practice.

We will continue to lead Project Bloom, the multi-agency group set up to tackle pensions scams. We work in partnership with regulatory, law enforcement and industry partners on communications campaigns, intelligence-sharing and development of enforcement, legislation, and industry-led prevention measures. Our casework has highlighted the involvement of organised criminals and the shared use of professional introducers, and we will take action to prosecute fraudsters who steal money belonging to pension savers, publicising case details, including sentences, as a deterrent.

We will take forward our segmented and proactive approach to risk and intervention, with a focus on sponsor support and adequate deficit repair contributions to reduce recovery plans to appropriate levels.

We will be engaging with more schemes than before to ensure that pension savers are treated fairly and that disproportionate dividends are not being paid at the expense of cash to repair pension deficits. This will include contacting the trustees of a number of schemes before their upcoming valuation where we are concerned about possible unfair treatment of the scheme relative to the shareholders.

While we continue to work with trustees of DB schemes to ensure members receive the pensions promised to them, we are also working with government on improvements and clarifications to the funding framework set out in its White Paper proposals which we hope will become law. We are drafting a new DB funding code which will explain clearer funding standards and provide clarity to trustees and sponsoring employers on our funding expectations. It will help trustees and employers deliver good outcomes for their schemes and should, alongside any expansion of our powers, better equip us to take enforcement action. We will be engaging with the industry on the revised code, beginning with a consultation later this year.

New types of pension arrangements, such as DB scheme consolidators and collective defined contribution (CDC) schemes, are new areas of regulation for us, and we will be working over the next year to ensure the necessary protections for members are put in place. Where appropriate we will use the full extent of our powers to ensure the security of members’ benefits and the safeguarding of the Pension Protection Fund (PPF).

AE is now an accepted part of running a business, with the vast majority of employers doing the right thing for their staff and setting up a qualifying pension scheme where they need to. However, we will target those employers that fail to meet their workplace pension responsibilities and take action against them where appropriate.

We will be gathering real time information from Her Majesty’s Revenue & Customs (HMRC) to help us identify employers that fail to enrol new workers or pay contributions.

The payment of pension scheme contributions is central to ongoing compliance. In April 2019, minimum contributions increased from 5% to 8% of total qualifying earnings and, together with the DWP and the pensions industry, we will be keeping a close eye on the impact of the increases. Our recent thematic review on maintaining contributions highlighted variances in monitoring and reporting payments failures by scheme providers. We will prioritise ongoing engagement with a number of schemes to ensure compliance with the reporting late payment of contributions codes of practice.

We will continue to intervene using a range of enforcement tools that escalate in severity where employers or their advisers persist in flouting or disregarding the law.

There are a multitude of challenges facing UK businesses. Most prevalent at this time is the ongoing uncertainty around the UK exiting the EU. However, there are many other challenges that are affecting industry and the way it operates. These range from perennial issues like ongoing automation, changing working practices, and sustainability, to shorter term developments like new legislative requirements. The impact of these changes will affect different sectors in varying ways and the ability of businesses to adapt will be a determining factor in their success.

Equally, there are significant challenges and changes facing the pensions sector, many of which are reflected by government-commissioned reviews. The Kingman review called for greater powers to ensure good corporate governance and reporting. The Competition and Markets Authority made recommendations that require trustees to have more robust processes for appointing and monitoring investment and fiduciary managers, and the DWP has consulted on wider investment, innovation and consolidation of DC schemes.

We will continue to work closely with government and with our partners and other regulators to help pension schemes navigate an uncertain social, political and economic landscape. In March 2019 we published our Annual Funding Statement for DB schemes and will keep this under close review in coming months.

The requirements for good scheme governance were enhanced by the European Directive on Institutions for Occupational Retirement Provision (IORP2). We will consult on a new code of practice this year to set out our expectations for effective scheme governance in line with these requirements and our continued focus on good governance.

We are an organisation that has changed significantly and will continue to do so over the course of this Corporate Plan period. As a result of our TPR Future programme, we have developed new ways of working and reorganised our frontline operations.

In the next year, we will be proactively contacting more schemes than ever before, drawing on the data and intelligence we hold. We will extend our regulatory grip to higher numbers of DB, DC and PS schemes, making the best use of our resources to positively influence behaviours and improve outcomes for pension savers. We will also be developing our strategic framework, evolving our longer-term view and using it to focus on and guide our priorities for future plans.

We will continue to develop our systems, operations and data so they are appropriate, targeted and efficient in delivering good outcomes for pension savers.

As our biggest asset, our people remain central to our success. We will continue to develop our people, their skills, and the capabilities we need to meet the challenges we face as well as maintain an engaged and diverse workforce that is focused and committed to the outcomes we seek.

Evaluation

We have been developing our evaluation framework during the course of our previous Corporate Plan. In particular, we have been establishing the longer-term outcomes we are seeking to achieve and the set of indicators we will use to demonstrate progress towards those outcomes.

Alongside this we have developed our performance framework and the set of Key Performance Indicators we will use to demonstrate our performance against our corporate priorities. The table below describes our framework:

To protect the benefits of members of occupational pension schemes To protect the benefits of members of personal pension schemes (where there is a direct payment arrangement) To promote and to improve understanding of the good administration of work-based schemes To reduce the risk of situations arising that may lead to compensation being payable from the Pension Protection Fund (PPF) To maximise employer compliance with employer duties and the employment safeguards introduced by the Pensions Act 2008 (AE) To minimise the adverse impact on the sustainable growth of an employer within DB scheme funding
Our outcomes
Participation: we want to increase participation in workplace pensions Protection: we want to protect members and the PPF Accountability: we want to hold those we regulate to account Confidence: we want to increase people’s confidence in the security and quality of workplace pension savings
Our outcome indicators
Automatic Enrolment Payment of Contributions Good Governance Appropriate Funding Record Keeping Regulatory Interventions Member Confidence Voluntary Contributions

Read more about our outcomes

Our corporate priorities
1. Extending our regulatory reach with a wider range of proactive and targeted regulatory interventions 2. Providing clarity and enforcing against the high standards of trusteeship, governance and administration we expect 3. Intervening where necessary so that DB schemes are properly funded to meet their liabilities as they fall due 4. Ensuring staff have an opportunity to save into a qualifying workplace pension, through auto enrolment 5. Enabling workplace pensions schemes to deliver their benefits through significant change, including responding to Brexit 5. Building a regulator capable of meeting the future challenges we face
Our key performance indicators
1. Master Trust Authorisation 4. Scheme returns 7. DB case outcomes 10. Qualifying schemes in place 13. Clarity of regulatory expectations 16. Employee engagement
2. Supervision 5. Content management 8. Deficit repair contributions 11. Automatic enrolment of staff 14. Consolidation of schemes 17. New operating model
3. New regulatory approaches 6. Data standards 9. Recovery plans 12. Timely contributions 15. DB funding code of practice 18. Implementation of new systems

Read more about our key performance indicators

We will track our progress against this framework over the course of this plan and provide a review of our performance at the end of each financial year in our Annual Report and Accounts.

We provide more detail on our key outcome and performance indicators below.

Our Outcomes

Our work as a regulator takes place in the context of broader public policy objectives for pensions, ensuring individuals save enough to have a decent income in retirement.

This Corporate Plan has been developed in alignment with the outcomes described below. These are closely aligned to our statutory objectives and sit in the broader context of delivering good outcomes for pension savers. Many contributing factors are outside of our direct control, but we will play our part in achieving these over the longer term.

We have defined the following key outcomes and associated indicators:

TPR external outcomes Measure
Participation: we want to increase participation in workplace pensions Proportion of staff put into a qualifying scheme
Proportion of employers that make contributions to schemes before they become significant late payments
Protection: we want to protect members and the PPF Proportion of members in DC schemes that are demonstrating good governance
Aggregate funding ratio for DB schemes
Accountability: we want to hold those we regulate to account Average scheme record-keeping scores
Proportion of schemes that have been subject to a risk-targeted regulatory intervention
Confidence: we want to increase people’s confidence in the security and quality of workplace pension savings Proportion of members in pension schemes who are confident in pensions compared to other forms of saving.
The amount of voluntary contributions made above minimum levels

We will use these measures as well as other sources of information available to us to demonstrate progress towards the outcomes on an annual basis. This will enable us to demonstrate a broader and longer-term view of the effectiveness of our performance.

Key Performance Indicators

We will use these indicators, as well as other sources of information available to us, to demonstrate progress towards the outcomes on an annual basis. They will enable us to demonstrate a broader and longer term view of our performance.

The table below outlines our KPIs and their alignment to our corporate priorities:

Extending our regulatory reach with a wider range of proactive and targeted regulatory interventions

Providing clarity, promoting and enforcing against the high standards of trusteeship, governance and administration we expect
  1. We will authorise all eligible master trusts within the statutory timescales
  2. We will undertake supervision of the most strategically important schemes
  3. We implement five new regulatory initiatives based on our core regulatory risk assessment
  1. Schemes have provided their scheme returns to us in line with requirements
  2. We will establish our content strategy and framework for all our publications
  3. We will support development of and design our approach to deliver the required data standards for the pensions dashboards

Intervening where necessary so that schemes are properly funded to meet their liabilities as they fall due

Ensuring staff have an opportunity to save into a qualifying workplace pension
  1. We will increase the number of DB case outcomes using our powers
  2. We will increase the deficit repair* contributions in DB schemes
  3. We will reduce the length of recovery plans*
  1. Employers have a qualifying scheme for automatic enrolment in place
  2. Staff have been put in a qualifying scheme
  3. Employer make accurate and timely contributions to their schemes on behalf of their workforce
Enabling workplace pensions schemes to deliver their benefits through significant change, including responding to Brexit Building a regulator capable of meeting the future challenges we face
  1. We will publish our annual funding statement and other forms of guidance as necessary to outline our expectations
  2. There are a reduced number of schemes in the pensions landscape
  3. We will consult on and subsequently publish a revised DB funding code of practice**
  1. We have high employee engagement
  2. We have implemented the new operating model resulting from TPR Future
  3. We will commence the design and implementation of new systems to support our regulatory functions

* These KPIs can be subject to political and economic factors that may influence the result – we will distinguish our performance from these at year end.

* * subject to the legislative timescale

Our structure

Over a number of years we have been growing as an organisation, in remit and, consequently, in size. As we have been growing we have allocated proportionally more resource to our regulatory front line. Our division of resources going forward shows our new strategy and risk directorate and is representative of an increasing allocation to delivering change over the course of this plan.

Staff numbers

The table below shows the 2018-2019 actual full-time equivalent (FTE) staff numbers, and the projected average up to 2021-2022. The increase in 2019-2020 in levy reflects the additional staff required to fulfil our broadened responsibilities and to implement our new regulatory approaches. Staffing levels in AE remain broadly similar over the course of this plan. This will be reviewed and adjusted accordingly once the design of our new strategy and operating model has been confirmed.

FTE 2018/19 2019/20 2020/21 2021/22
Levy 436 515 525 522
AE 224 218 218 252
Total 660 733 743 774

We expect our resources to be allocated across the organisation in 2019-20 as follows:

Financial summary

Funding

Our funding is derived from two main sources: a grant-in-aid from the DWP which is recoverable from a scheme levy relating to Pensions Act 2004 duties, and a separate grant-in-aid from general taxation relating to the AE programme arising from Pensions Act 2008 duties.

Since the last Spending Review settlement in 2015, we obtained agreement from DWP for additional spending for 2018-2019 and future years, as outlined in the 2018-2019 Corporate Plan. This was to address new challenges including implementing the new master trust authorisation regime and increasing our frontline resources to undertake higher volumes of casework more quickly and more proactively. It also included our work to increase our reach as part of the TPR Future programme - our new approach to regulation.

We have identified and agreed with DWP £7.6 million additional levy funding for 2019-2020. £1.2 million of this increase is to fund a scams campaign to raise awareness, £1.3 million is to support ongoing work in respect of the Pensions Bill, £0.4 million is required to support policy work in relation to the Pension Dashboard and £1.8 million is for the additional employer pension contributions to reflect increased contribution rates (applicable across the public sector). The balance of the funding is to address increased costs in relation to the overall growth of TPR which includes increased capability for information technology, transformation and governance.

2018-2019 financial results

The table in the next section compares the forecast 2018-2019 full year spend to the budget. The categories shown illustrate the major areas of expenditure. Our spend in 2018-2019 of £85.7 million is £3.0 million below the original budget agreed with the DWP of £88.7 million. The main reasons for this are lower regulatory case spend (£1.4 million) than originally budgeted, reduced costs in relation to the compliance regime for AE (£0.9 million) and reduced depreciation due to an extension to the life of the AE case management system (£0.5m) and various other underspends across the organisation.

2019-2020 budget

The budget for 2019-20 is almost £99 million, with key expenditure broken down in the table below:

£000s 2018/19 actual* 2018/19 budget 2019/20 budget
Income (82) (16) (76)
Staff Costs 49,405 49,923 55,339
Other Staff Costs 3,010 3,007 3,588
Consultancy / Professional Services 8,407 9,643 9,680
Communications 1,737 1,746 1,678
Managed Contracts 16,920 17,442 20,234
Accommodation / General Office Costs 4,756 4,560 6,752
Telephony / Internet 249 302 244
Fixed Asset Costs 410 700 566
Depreciation 894 1,354 952
Total 85,706 88,661 98,957

* Subject to audit

This shows an increase of £13.3 million against the full year spend in 2018-19.

The main reasons for the increase are:

  • A £5.9 million increase in staff costs due to growth in FTE staff, primarily as a result of implementing our new operating model together with the introduction of the master trust authorisation regime. It also reflects the increase in employer pension contributions for TPR as an employer from April 2019.
  • An increase of £3.3 million in managed contracts due to costs in relation to the AE regime and increase in support contracts to reflect organisational growth.
  • Increases of £2 million in accommodation and general costs from technology investments in new systems and the overall growth in TPR
  • An increase of £1.3 million in consultancy/professional services to reflect expected case costs due to new regulatory approach and delivery of projects
  • Smaller increases across other cost areas totalling £0.8 million

A comparative analysis of the full year actual spend for 2018-2019 compared to the budget over the future three years, split by our levy and AE funded activities, is shown in the table below. We continue to revisit and update the future spend profile each year to reflect the latest known information and plans.

The levy costs increase over the period to reflect the growth of staffing to respond to our growing regulatory remit and approaches, and our technology and data investment plans for the next three years. The AE costs fluctuate over the next three years, reflecting the cyclical nature of employers’ AE duties, particularly re-enrolment dates, but with an increase in expenditure in 2019-20 as we begin a programme of work to prepare for the future AE strategy and operating model. This is required as a result of our key outsourcing contract ending during 2021.

  2018/19 (£000) 2019/20 (£000) 2020/21 (£000) 2021/22 (£000)
Levy 50,853 61,155 69,302 70,134
AE 4 34,853 37,802 41,434 35,954
Total 85,706 98,957 110,736 106,088

4 These figures are provisional funding assumptions and subject to change once Government fiscal events have been completed

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Corporate Plan 2019 - 2022
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Published: May 2019