Skip to main content

Making workplace pensions work

Menu

Compliance and enforcement bulletin April 2025 to March 2026

This bulletin marks the first of our annual editions and provides information about how we have used our enforcement powers. By publishing these statistics and analysis, we aim to promote transparency, help employers, advisers, trustees and administrators understand the compliance and enforcement interventions we undertake, and support greater understanding of our regulatory expectations. Where standards fall short or harm occurs, we will act decisively and proportionately to address risks, secure compliance and protect members.

Our enforcement approach prevents harm before it happens by setting clear expectations and helping those we regulate understand and meet their responsibilities. Through guidance, education and engagement, we support compliance, raise standards across the pensions system, and help deliver good outcomes for members. We focus our regulatory activities on the risks and harms that matter most to savers, using the right tools at the right time to prevent problems from becoming more serious.

On this page

Selected powers used for regulation of schemes

Table 1: Powers used for regulation of schemes

Power Description Number in period
Trustee appointments The power to appoint trustees to schemes (a) to secure that the trustees as a whole have, or exercise, the necessary knowledge and skill for the proper administration of the scheme, (b) to secure the proper use or application of the assets of the scheme, and/or (c) otherwise to protect the interests of the generality of the members of the scheme. 2
The power to appoint trustees to schemes to secure that the number of trustees is sufficient for the proper administration of the scheme under Section 7(3)(b) of the Pensions Act 1995. 271
Power to vest or transfer property as a consequence of appointing or removing a trustee under Section 9 of the Pensions Act 1995. 2
Trustee suspensions The power to suspend a trustee either (a) whilst we are considering making a prohibition order against them, or (b) if proceedings have been issued against them for an offence involving dishonesty or deception, or (c) pending consideration being given to the institution of proceedings for an offence involving dishonesty or deception. 0
Power to extend the period of suspension. 0
Trustee prohibitions Power to make a prohibition order under Section 3 of the Pensions Act 1995. 2
Special Procedure Where TPR considers that there would be an immediate risk to members interests or scheme assets if a warning notice were to be issued. 0
Mandatory penalty notice The Occupational Pension Schemes (Charges and Governance) Regulations 2015 require us to issue a mandatory penalty where no chair's statement has been prepared or we are of the opinion that the statement does not comply with the requirements prescribed for a chair's statement in the Occupational Pension Schemes (Scheme Administration) Regulations 1996. 75
Other mandatory penalty notice. 0
Scheme return enforcement Trustees have a legal obligation to give us information about their pension scheme by completing a scheme return when required, and an ongoing duty to ensure our records are maintained with up-to-date registrable information. A financial penalty under Section 10 of the Pensions Act 1995 may be imposed for this failing. 0
Audited accounts enforcement Trustees or scheme managers of most schemes are legally required to obtain audited accounts annually within seven months of the scheme year end. Failure to do so may result in a financial penalty. 0
Information gathering Our formal information gathering powers under Section 72 of the Pensions Act 2004. 250
Regulatory intervention reports Section 89 of the Pensions Act 2004 gives us the power to publish information on cases where we have exercised or considered exercising our powers. 7
Clearance A statement that we will not use our anti-avoidance powers to issue a) contribution notice or b) financial notice directions or c) both (note 1) in relation to a defined benefit occupational pension scheme. 2
Inspection and warrants Statutory inspection powers under Sections 73 to 78 of the Pensions Act 2004. 0
Production order A High Court Order under Section 345 of the Proceeds of Crime Act 2002 requiring the production of specified material. 1
Provision of information by interested party. Section 18(A) Proceeds of Crime Act 2002. 0
Confiscation order A Crown Court Order under Section 6(1) of the Proceeds of Crime Act 2002 requiring a convicted defendant to pay a sum of money representing the benefit from their offending. 0
Restitution order A High Court Order under Section 16 of the Pensions Act 2004 requiring a person to put right a misuse or misappropriation of pension scheme assets in which they were involved. 0
Restraint order A High Court Order under Section 41(1) of the Proceeds of Crime Act 2002 requiring the restraint of assets. 0
Criminal Fraud by Abuse of Position under Section 4 of the Fraud Act 2006. 0
Restriction on Employer Related Investments under Section 40 of the Pensions Act 1995. 0
Improvement/third party notice Notices containing directions for a person to take steps to enable compliance with pensions legislation or remedy any non-compliance. 2
Regulated apportionment arrangement (RAA) The application, subject to conditions, to separate a scheme from its employer. It must be approved by us and the Pension Protection Fund must confirm that they do not object to the RAA. 0
Master trusts Add a scheme to the list of authorised master trust schemes under Section 13 of the Pension Schemes Act 2017. 0
Removing a scheme from the list of authorised master trust schemes. 0
Confirm a triggering event notified by a master trust has been resolved. 6
Other master trust powers. 1
Value for members enforcement Most trust-based pension schemes with defined contribution benefits and less than £100m assets under management must annually complete a detailed value for members assessment. Should they conclude that their scheme does not offer good value they must either make improvements or consider transfer of money purchase benefits/wind-up of scheme. Failure to complete the assessment may result in us issuing a financial penalty and considering further enforcement action. 29
Notices containing directions for a person to take steps as directed to enable compliance with pensions legislation or remedy any non-compliance. 1
Climate change enforcement Large schemes and authorised master trusts must produce and publish a Task Force on Climate-Related Financial Disclosures (TCFD) report within 7 months of scheme year end. Occupational Pension Schemes (Climate Change Governance and Reporting) Regulations 2021 require us to issue a mandatory penalty to schemes failing to publish a link to their report on a publicly accessible website. 0
Other Other powers. 24
Total 675

Table 2: Reviews

Reviews Number in period
Requested 9
Completed 17

Table 3: Outcome of reviews

Outcome of reviews Number in period
Confirmed 4
Revoked, substituted or varied 11

Automatic enrolment

Table 4: Automatic enrolment cases closed in the period

Cases closed in the period 86,547

Table 5: Selected powers used in the period

Power Number in period
Information notice 131
Inspection 187
Warrant 0
Compliance notice 51,241
Unpaid contributions notice 29,314
Fixed penalty notice 33,362
Escalating penalty notice 12,678
Production order 0
Total 126,913

Table 6: Reviews 

Reviews Number in period
Requested 9,062
Completed 5,715

Table 7: Outcome of reviews 

Outcome of reviews Number in period
Confirmed 1,472
Revoked, substituted or varied 4,243

Table 8: Tribunals 

Outcome of reviews Number in period
Requested 342
Defended 211
Not defended 130

Table 9: Outcome of defended tribunals

Outcome of reviews Number in period
Confirmed 221
Revoked, substituted or varied 1

Table 10: Ongoing tribunals

Outcome of reviews Number in period
Ongoing tribunals where the decision has yet to be made on how to respond 1
Defended tribunals still ongoing at the end of March 2026 46
Is this page useful?

Thanks for your feedback.