TPR sets expectations on “hidden” concentration risks in pension portfolios
Ref: PN26-18
The Pensions Regulator (TPR) has today published guidance to help trustees identify and manage potential hidden AI-related investment exposure as artificial intelligence becomes increasingly influential across global markets.
Investment in AI-related activity is growing across global markets, with reports showing that global private AI investment has more than doubled in 2025, rising by 127.5% year-on-year.
This brings new risks and opportunities for pension scheme investing, but because AI is increasingly embedded across sectors, even a diversified portfolio may have hidden exposure to common AI-related risks.
TPR expects all schemes to maintain high standards of investment governance and manage risk over the short, medium, and long term.
That is why it has published the new guidance aimed at helping trustees better understand and manage these newly emerging risks. It asks trustees to look across their whole portfolio, rather than considering individual funds or asset classes in isolation, giving practical guidance on how to manage potential risks and opportunities.
Ben Gunnee, Executive Director of Market Oversight at TPR, said: “We expect all schemes to maintain high standards of investment governance and manage risk over the short, medium and long term.
“That is why trustees should assess their AI-related exposure, test portfolio resilience and challenge advisers now to understand how market developments could affect their investments under different market conditions.”
TPR expects trustees to:
- assess total portfolio exposure, including direct and indirect AI-related exposure across asset classes
- use scenario analysis to test portfolio resilience under severe but plausible stressed market conditions
- review whether diversification would remain effective if correlations changed during a downturn
- challenge investment advisers and managers on how market developments could affect the scheme’s investments and objectives
- take proportionate action that reflects the scheme’s circumstances
Read AI concentration risk: Action for trustees.
Notes for editors
- The latest Stanford HAI 2026 AI Index Report found that global corporate AI investment more than doubled in 2025.
