The government is consulting on various changes to trustee requirements, from how to implement a directory, to imposing limits on the length of tenure and number of appointments trustees can hold, as well as asking about conflicts, member voice, a public trustee for problem schemes, and a register of administrators with a possible power to deregister them. The consultation published on Monday closes on 5 March 2026.  

As pension assets have grown and auto-enrolment has brought millions into the system, the government and Pensions Regulator have become increasingly concerned that trustees should have a higher level of skills and knowledge to be effective stewards of pensions. Governance requirements have been ramped up as a result, which in turn has led to professional trustees, sole corporate trustees and master trusts now dominating the UK pensions landscape.

However, this professionalisation of pensions has introduced a greater commercial element – leading to new concerns, mainly around conflicts of interest, market concentration and a lack of member voice.

Building on a 2023 call for evidence by the previous government, the Department for Work and Pensions has now picked up several of these issues, also raised by the Pensions Regulator in the past, in a new trusteeship consultation published today. 

It proposes “increasing the knowledge and understanding requirements for trustees, with centrally set standards and accreditation for professionals; and measures to improve the diversity of trust boards”. 

The questions range from preventing and managing conflicts that can arise when professional trustee firms offer other services or when trustees of defined contribution master trusts are appointed by the scheme funder, to a proposed new public trustee to replace the current roster TPR relies on when it appoints a trustee to a scheme. 

On standards and conflicts, the government points to international evidence suggesting a balanced representation of stakeholders, higher level of expertise and codes of conduct can improve governance; and it points to Australia’s 12-year tenure limit, individual director skills requirement and board performance review in the context of ‘megafunds’. 

There are questions on whether to introduce a limit on the number of appointments professional trustees can have at any one point to make sure they dedicate enough time to each scheme; on introducing statutory standards for professional trustees; and bringing in an enhanced code of practice for sole trustees. 

The government is also concerned about a lack of diversity among trustees, and wants to know how to attract a more diverse talent pool and how to ensure the member perspective can be taken into account, since numerous structures do not require member-nominated trustees. 

As the pensions dashboard and value for money requirements are introduced, the DWP is beginning to look at pensions administration – asking what role TPR should play in ensuring possible disorderly market exits by administrators. It is therefore considering giving TPR the same levels of regulatory oversight as the Financial Conduct Authority regarding administrators, and asks if administrators should be registered with TPR, and if TPR should have the power to deregister them. 

The regulator is backing the government's focus on governance: "Strong trustee boards and robust governance are the bedrock for delivering good outcomes for savers. Fiduciary duties are a powerful force for good,” said TPR chief executive Nausicaa Delfas.  

 

“As the market evolves, we want to make sure acting in members’ best interests remains at the heart of workplace pensions with the right skills, structures, systems, processes and controls, and we encourage industry to respond to this important consultation,” she added. 

Rachel Croft, who chairs the Association of Professional Pension Trustees, agreed that trustees need to have the right skills and experience, and pointed out that the APPT recently updated its code for sole trustees to raise standards, saying the association is committed to regular reviews. 

 

“We welcome the trustee directory, subject of course to it not being excessively onerous administratively.  We also welcome the questions on accreditation and standards as areas we are already examining and looking at with key stakeholders,” Croft said. 

 

However, the APPT is less happy about tenure limits. Croft said: “One caveat at this early stage in our consideration of the consultation document – naturally we advise careful consideration of applying any restrictions to appointment numbers or terms, given the need to manage market capacity and encourage the continuation of training and development for professional trustees.”

The Association of Member Nominated Trustees welcomed the consultation, saying it reflects recent concerns about the inherent risks of conflict and concentration in the sole trustee market and the lack of member voice as schemes consolidate towards the government's vision of fewer, larger pension schemes. 

Co-chair of the AMNT Maggie Rodger said the consultation states that ‘trusteeship is a vocation’, saying: “This is particularly evident in the role of member-nominated and other lay trustees, who engage in trusteeship because of their direct connection to the scheme and its beneficiaries. For the sake of members, it is essential to find ways to preserve that voice within larger multi-employer and master trust schemes, whether [defined benefit], DC, or [collective DC].” 

She argued the most effective way for that voice to be heard is through representation on the governance board, “supported by appropriate training and experience tailored to the scheme”. Some schemes such as master trust Nest have a member ‘panel’, where members can voice their views but hold no decision power like MNT have. 

Rodger said a loss of member voice could increase conflicts of interest and encourage “groupthink” among a limited pool of professional trustees.

Helen Forrest Hall, chief strategy officer at trustee training and accreditation body the Pensions Management Institute, said the consultation is an important step towards creating a higher bar for trusteeship. 

 

“The pensions industry is undergoing profound change and those at the forefront - trustees and administrators - must be equipped with the skills and expertise to deliver for savers. As complexity grows, standards need to rise to safeguard members and ensure confidence in the system,” she said. 

 

The Society of Pension Professionals also welcomed the consultation. Barry Mack, chair of the Administration Committee at the Society of Pension Professionals said: “The SPP very much agrees with the government that good governance is vitally important and that pension schemes must be overseen by trustees that have not only the skills and knowledge to navigate the changes to come, but also members’ best interests consistently front of mind.”

Proposals for statutory oversight over administrators did not find favour with the Pensions Administration Standards Association. PASA chair David Fairs said the association believes the right approach is for more schemes and administrators to seek PASA accreditation rather than introducing a new state-run accreditation system "which may be slower to adapt to market developments or emerging risks".

However, PASA supports the focus on orderly market exits in case a pensions administrator fails and has already started working on practical frameworks with the Pension Protection Fund and TPR, he said.

Pensions UK said it was right to look at governance in the context of a consolidating pensions market but highlighted that the burden must remain proportionate.

Tiffany Tsang, head of DB, LGPS and investment, said: “Trustees across all scheme types need the right environment and conditions to do their jobs effectively. Ensuring they have the appropriate skills and capability will be central to success, alongside a proportionate approach that reduces unnecessary burdens and allows trustees to focus on their core fiduciary responsibilities.”

The government is apparently aware of being at risk of sending conflicting messages as its focus on governance could run counter to a government declared push for 25% less red tape.

The consultation states: “Effective regulation provides important protections, but excessive regulation and oversight undermine these benefits – inhibiting growth, innovation and investment.”

The DWP adds: “We will continue to work with the Pensions Regulator (TPR), as they deliver their commitments to support growth, including reviewing areas where unnecessary burdens on schemes can be reduced.”