Skip to main content

Your browser is out of date, and unable to use many of the features of this website

Please upgrade your browser.


This website requires cookies. Your browser currently has cookies disabled.

The Evolution of Master Trust Supervision

Tuesday 9 July 2024

Neil Bull, Executive Director of Market Oversight at The Pensions Regulator gave a keynote speech at the Master Trust Conference entitled The Evolution of Master Trust Supervision.

Hello, I’m Neil Bull, TPR’s Executive Director of Market Oversight.

Some of you in this room I know. But many of you I don’t. So, I’ll start by saying: I’m one of you – a pensions person.

I have worked as an actuary in large consultancy. An investment consultant and asset manager in individual pensions plans. And been a chair of a significant single employer defined contribution (DC) trust.

I know what it’s like to advise schemes. To be the decision-maker in schemes. And now, thanks to six years at the regulator, what it’s like trying to engage with schemes and do the best for savers across a whole market.

I know that you, the people in this room, want the best possible pensions outcomes for your savers. I want that too.

That is why, as Nausicaa outlined, we are changing as a regulator.

As part of this change, I have been appointed as the Executive Director for Market Oversight to lead a new division.

Our job is to build a deep understanding of both market-wide and individual schemes’ risks and opportunities so that we can protect, enhance and innovate in savers’ interests.

To do this, Market Oversight will bring together multi-disciplinary teams – with experts in governance, investments, business analysis, communications and more – to work with you to deliver enhanced outcomes for savers.

Market Oversight

For many years we have worked this way with the largest defined benefit (DB) pension schemes – the £1.4 trillion of assets that they contain rightly drew our focus.

But now as many master trusts start their evolution towards becoming systemically important entities, and reflecting the volume of savers now within DC, we are rebalancing our focus.

To make sure that you, master trusts, are the gold-standard for pension provision in the UK.

Clearly, the authorisation and supervisory regime of master trusts has been a success so far. Predicted unwieldy exits from the market, with the potential to harm savers, have not emerged.

Instead, we have seen high levels of governance and administration relative to the rest of the market. And refined, professional operations driving consolidation by opportunity, not by necessity through difficult circumstances.

But if the challenge of the last decade was getting people saving into high-quality pension schemes. The challenge of the next is to ensure value.

That is why this week I appointed Sam Grutchfield as interim Director of DC and Master Trusts Supervision to lead our engagement with the market.

As the architect of the legislation which brought master trusts to life – first at DWP and then at TPR – he is well placed to work with you all to make this vision a reality.

And in the past, you may have seen your interaction with us as a regulator purely in terms of compliance.

While that is still critically important, I would also urge you to think of us in terms of a partnership.

You are not pure businesses, where profit is the only motive. As schemes, with regulated trustees, you are also there to act in your members best interests.

A duty I know that your trustees live and breathe. And that is why I want to know what keeps you up at night. To hear what risks are lurking in the market.

I want you to be open with us and share your candid thoughts.

To help us mitigate harms and identify opportunities for savers in a changing pensions landscape.

We will consider your ideas and worries and explore them - building sophisticated evidence bases which help us understand the bigger picture.

We won’t keep this to ourselves. Instead, we will play these insights back to you all – so you can not just seek to comply with the basics, but truly deliver the best for savers.


Value has to be the guiding light for all that we do. For our engagement with master trusts that means:

  • a focus on investments
  • a focus on data quality and standards
  • a focus on innovation at retirement

Some of you will already have noticed a difference in how we have engaged with you on investments.

Bringing together a multi-disciplinary team, engaging not just your trustees but also your investment and strategic experts, really listening to what you say, and commissioning work in response.

The first steps towards a collaborative supervisory approach with a mindset of continuous improvement.

We know that for many years the conversation when it comes to value has been on cost alone. And with our forthcoming value for money framework we want behaviour change to focus on genuine value.

The investment returns, and services received, for the price paid.

Through the framework you have heard us say that we believe disclosure can put the wheels in motion for effective competition and we continue to work in partnership with the FCA and DWP to bring this into law.

But we cannot and will not wait for legislation to make sure savers’ needs are met.

Instead, expect us to probe and challenge more on the outcomes you are delivering for savers through your approach to investments.

Expect us to ask you about how you are seeking the best possible long-term risk-adjusted returns.

But also expect us to look more broadly at your investment governance practices and investment decision-making in the round.

For example, seeking to understand if climate reporting disclosures are really the product of your strategic decision-making and protecting savers now and in the future – or something you view as a burden that just needs to be complied with.


We are entering an era of data and disclosure. This presents huge opportunities for us all.

If pensions data is trustworthy.

If pensions data is secure.

And crucially, if pensions data is in the open, we can all achieve much more.

We will be encouraging this as a regulator conceptually. But also backing it practically via our supervisory approach – requesting deep dives into the systems and processes of your schemes to really lift the bonnet on how you operate.

Our visits need not be cause for concern but seen instead as a learning opportunity for us both.

This will mirror the activity we see in the private sector when master trusts showcase their offer to employers explaining their operations.

Finally, you should expect to see us talk to you more and more about how you help savers into and through retirement.

Given that master trusts have only been in existence for a decade or so, naturally the focus so far has been on accumulation.

But the point of building a pension is to support yourself in retirement. And we have to get this right for the generations of savers to come.

Pensions dashboards will help savers understand what they have saved so far, and potentially how they can plan for the future. And a small pot solution will help make that picture clearer.

But we need to work with you all and build consensus on what good looks like both in terms of retirement products and services.

But also guided decision-making and communications so that savers make the best retirement choices for their personal circumstances.

That is why we’d encourage you to approach us with your emerging propositions so that we can plot a way forward together to tackle the 'knottiest, hardest problem in finance'.


In the spirit of our changed way of working, today we have two breakout sessions where we really want to hear what you think, and Simon will explain more how these will work in a moment.

To facilitate discussion, we are going to put forward questions and statements for your thoughts, reaction, and comment. It’s an opportunity to comment on both short-term future innovation such as dashboards, and medium-term ideas like pot consolidation.

We would also be interested on your views about longer-term regulation matters and how you would feel they might best develop.

We will take note of comments and undertake to continue the dialogue with you over time.

I look forward to hearing what you think.

Thank you.

Share this page

  • Facebook
  • Linked In
  • Twitter