Delivering a modern regulatory system that drives better outcomes for savers
Speech by Nausicaa Delfas at the Pensions Expert Conference on 26 November 2025 about delivering a modern regulatory system that drives better outcomes for savers.
Key points
- This is a pivotal moment in pensions: our challenge now is to change the trajectory of the system as a whole, to course correct and to set a new generation of savers on a path to a sustainable and adequate income.
- The Pensions Regulator’s (TPR's) priorities are to make sure schemes are well run, that they deliver value, and ensure default solutions at retirement.
- TPR will work with industry and government to ensure successful implementation of the pensions reforms.
Thank you, John for that kind introduction.
It’s never easy speaking after the Chancellor – especially when we are all absorbing the Budget.
But our role at The Pensions Regulator is to think beyond the next fiscal year, to the next generation.
A pivotal moment for pensions
Because at the moment, the pensions system is unfinished business.
Even though it has taken a giant step forward in recent decades, with private pension participation doubling, which is a fantastic policy success, there are still too many people under saving for retirement. In fact, 14.6 million – more than the populations of London, Birmingham, Manchester, and Liverpool combined.
This means that without change, we will have a generation facing a retirement it cannot afford.
The people I meet who are most worried about their pensions are often approaching midlife, when retirement is not so distant.
And this is not just a challenge for those individuals.
It is a challenge for all of us:
Our society was not built to support millions struggling to afford later life.
So we are at a pivotal moment:
Our challenge now is to change the trajectory of the system as a whole and to course correct, to set a new generation of savers on a path to a sustainable and adequate income.
The Pension Schemes Bill and the government’s Pensions Commission have given us a once-in-a-generation opportunity to rise to that challenge.
The Commission is clear that the new system needs to be adequate, fair, and sustainable – which means it has to be built to last for the next 30 years at least.
As regulator, a core part of our role in that course correction is to make sure schemes are well run, deliver value, and ensure default solutions at retirement.
So today, I will talk about how we are going to work with you to implement the pensions reforms successfully.
I am going to focus on three things: governance, value and retirement.
Governance and trusteeship
I’ll start with governance, and particularly trusteeship.
As pensions change, trusteeship should change too.
In a world with fewer, larger schemes, it is more important than ever that they are well-run.
One of our priorities as a regulator is to raise the standard of trusteeship.
The idea of a system with guardians at the centre, working each day to deliver the best possible value and security for savers is incredibly powerful, but we need to make sure trustees meet the right standards and are focusing on the right priorities.
Our role as a regulator is to support you to do that, champion you, and help the system to evolve, as requirements change.
But today, what it means to be a good trustee is evolving.
Schemes are consolidating.
We are moving to a world of mega funds and super funds and seeing the growing influence of professional trustee firms.
Our vision is that all schemes are run by highly skilled trustees, so that all scheme members benefit from better outcomes.
That is why we are shifting towards a prudential style of regulation and extending our oversight to professional trustee firms.
Across the board, we want to bring trusteeship into line with professional governance standards – learning from other sectors and applying best practices.
That means ensuring trustee boards have the skills and the cognitive diversity they need. Not just because that is best for millions of individuals, but also because it is in the public interest.
Part of the course correction we need is trustees taking greater responsibility for making sure those improvements happen.
At a minimum that means there should be high levels of corporate governance, robust data, clear communication, and effective cyber resilience.
Good scheme administration is critical to delivery of all these things. And our recent engagement with 15 pension administrators highlighted the importance of trustees and administrators working together to improve standards.
We are encouraged to find signs of progress; many administrators are becoming more strategic and resilient.
But challenges remain:
We want and expect to see improvement in administration through investment in technology and new skills, improvement in data quality, and better governance.
Resilience to cyber-attacks is particularly important.
Our updated cyber security guidance sets out how trustees and scheme managers can meet their duties to assess risk, ensure the right controls are in place, and respond to incidents.
We also want trustees to report significant cyber-related incidents to us to tackle the ongoing threat from cyber criminals.
I would urge all trustees and administrators to reflect on our findings and work together to find ways to better serve savers by improving on all these areas.
As the market evolves, trustees must take greater responsibility and accountability for ensuring those improvements happen.
If you are a trustee, it is your responsibility, and not one that can be delegated.
One catalyst for improvements in administration has been dashboards.
Dashboards and the transparency they bring should help savers take control of their pension journeys.
So, member data needs to be treated as a strategic asset.
We are now one year from pension schemes needing to fulfil their dashboards duties.
We recently published a market oversight report on data quality – and the good news is there has been significant progress.
But the robustness of controls and focus by trustees is mixed, and some schemes still have a long way to go to get their data dashboards-ready:
One in four still hold some form of non-digital data.
And fewer than three in five schemes are confident in the accuracy of their personal data.
With one year to go, improvement is needed, and we may look at further interventions in this area.
Good data management is not a one-off exercise; it is an ongoing process. Here and now, it enables good scheme performance. In the future, with the AI revolution, it could transform service offerings.
And it starts by recognising what we mean by good quality data:
Data that is complete, in a valid format, consistent with other data, timely, accurate, and, where appropriate, unique.
This cannot be an operational afterthought; it has to be a core accountability of governing bodies.
We are urging the pensions industry to work with us to drive up adoption of the latest technology and standards for data. An ecosystem with less friction will reduce burden on pensions schemes and present new opportunities. Our approach is adaptive and collaborative with savers at the heart of our vision.
Accountability runs at the heart of our workplace pensions system.
Many trustees understand the powerful force for good they represent and care deeply about the millions of members entrusted to their care.
This commitment must be seen across the board so that every trustee delivers on their promise to act in members’ best interests.
We will be holding structured roundtables in the next couple of months to discuss our vision for trusteeship, and you will be invited to apply through our usual channels such as the Newslink and the Master Trust Bulletin. And to help schemes capitalise on new digital and data opportunities our newly launched working group will support and drive innovation.
We all know about the problems which can constrain scheme governance: not enough time, costs are high, and budgets are limited, pensions are technically difficult to navigate, and the regulatory environment is shifting.
We want to discuss practical solutions with you, so my message to you is straightforward:
Please do join in, get involved, and help us give you what you need to raise the bar.
Value
Value for money
This brings me to a topic which is at the heart of achieving good outcomes for savers: delivering value for money – meaning net benefit: good investment returns and high-quality services received for the price paid.
For those of you who are defined contribution decision makers, I know you all want to achieve value for money for your savers and, as a regulator, we want to make that as achievable as possible.
It can’t be right that employers, and even providers, can’t make decisions based on clear comparable data. That schemes can’t learn from one another to reach ever higher standards. And that employers can’t pick a scheme, invested in a diversified range of assets that delivers the highest possible returns for their staff.
Across the reform agenda, we are working closely with the FCA and the DWP to make sure that the Pension Schemes Bill is effectively implemented.
Value for money is at the centre of the Bill, and we want to hear your views to make sure we get this right and introduce a framework that ensures DC pensions receive value for money by default and taking into account learnings from other jurisdictions.
We expect to launch a joint consultation on this early in the new year.
This framework should support trustees to make the changes they need to offer good value for money – which for some, will be crystal clear clarity that they should leave the market.
To help schemes improve their performance in advance of the Bill, following the launch of the consultation we will also launch a data survey with master trusts, in which we plan to ask for asset allocation and a sample of the investment performance metrics for different-aged member cohorts, as well as some contextual questions on the provision of this data.
We expect to publish the findings early in the new year – to help schemes understand what good looks like and to take steps to deliver more.
Pipeline of assets – our work on investment engagement
And what good looks like could mean a broader investment profile, and consideration of greater investment in the UK if it is in savers’ interests.
Plenty of UK sectors such as technology, science, and biotech are likely to grow in the coming years and decades.
But just because the opportunities are there does not mean it is easy for asset managers to make the most of them. They may struggle with valuations, liquidity or feel that funds available don’t meet the needs of their particular scheme.
At present, UK pensions lag far behind Canada, Australia, and New Zealand when it comes to investing domestically.
As you know, the Mansion House Accord was a commitment from industry to move the dial, 17 of the largest workplace pension providers say they plan to invest more in private markets by 2030, including in the UK. This has subsequently been built on by the so-called “Sterling 20”.
This has the potential to both unlock more capital for the economy, but crucially, also deliver the best possible long-term returns for savers.
To support the drive towards better member outcomes, this year we are also undertaking a market engagement exercise to understand more about the limitations, barriers, and enablers to pensions schemes investing in a range of opportunities and investment vehicles with an emphasis on opportunities in the UK.
As a regulator, we can use our unique position in the marketplace to be the interlocutor between government and industry to support you to make the most of those opportunities.
This builds on our work last year with new private markets guidance to help trustees improve outcomes for savers by properly considering the full range of options available.
Our focus on improving pensions investment practices is because we want better member outcomes. But as I said, this drive may also benefit the UK economy too. And through growth, we all benefit.
Retirement
In all this work, we must not forget the social purpose that the pension system was set up to deliver. To support people financially in later life.
That is why we also need to course correct in terms of savers’ options at retirement.
Most people want to know they will have an adequate income after they retire but the current system does not assure that.
At the moment, when people come to access their pots, they risk losing value, because only one in five have a plan for how to access their funds.
People need help to make sense of a decision that can be complex.
In the new system, we want savers to be better prepared, better informed, and better supported.
As you know, the Guided Retirement Duty requires trustees to make sure DC scheme members have good default options, with good support to choose another road should they wish.
With DWP, FCA and the Treasury we have introduced a working group to determine and test with stakeholders the detailed design of default pension plans. A key principle, one that I am passionate about, is that default pension plans should ordinarily provide an income in later life.
Over the next year, we will be engaging with the market via our supervisory approach. We want trustees to consider the design, cost, and overall value of decumulation solutions from now so that they are ready for when duties come into force.
Some schemes may wish to go further in their communications to members and offer something more tailored. That is why we are working with the FCA on their complementary Targeted Support initiative to make sure that in tandem, these reforms give savers the support they need at retirement.
Implementation and reducing the regulatory burden
I said at the start that it is our challenge as an industry to make sure savers have a sustainable income to last throughout their older life.
Although the proposals in the Bill are set to fix many issues in the market, it is only the start of our journey.
Once it is law, the core work of implementation will begin – and getting it right is critical.
So, it is a priority for us to work with you and the wider industry to get that implementation right.
We know that also means changing how we work as a regulator to become more efficient and effective.
We want to make it as easy as possible for you to understand what the government intends, adapt our approach to supervision and data asks where necessary, and make sure there is a smooth connection between investment and investable opportunities.
That means making it easier for industry to engage directly with us on innovations, which is why we launched our innovation service in May.
It also means consulting on new codes of practice, for example for multi-employer CDCs, and listening to your feedback.
And making sure our interactions with you are always purposeful, and that we are proportionate and reasonable in what we ask of you.
That’s why we are looking at how schemes can provide data to us in a way that limits the wider reporting burden and frees up your time.
We are working to reduce the burden of regulation. For example, in master trust supervision, we are aiming to reduce the number of evidence documents we require from the market by an estimated 50%. We also plan to review our regulatory capital reserving requirements for master trusts to ensure they are proportionate – and this could unlock hundreds of millions of pounds for investment.
For the more than 2 million employers who must comply with automatic enrolment duties, by using a smarter approach we expect to issue 25,000 fewer enforcement notices next year at the same time as maintaining high levels of compliance.
For all our regulated audiences, we are changing how we approach enforcement, and where we will take action. We are carefully reviewing all responses to our strategy consultation to make sure that every enforcement action we take protects savers, contributes to our wider policy outcomes and drives real changes in the market.
Conclusion
Pensions are in a moment of great change. And as we course correct onto a more sustainable path in the coming years, I look forward to working with you and the wider industry to focus on the three priorities I have set out today:
- improving governance
- delivering the best value for money for savers, and
- making sure that savers are well-informed about the choices they face at retirement
Meeting these challenges will shape how we move towards a more sustainable pension system.
And I know that together, we can ensure a higher quality of life for millions of people for decades to come.
