Regulator finds significant governance gaps between small and large pension schemes

Smaller schemes are more likely to show weaker trustee oversight, less robust risk controls and thinner evidence of value-for-members assessment, while larger schemes tend to operate more structured governance. For compliance and trustee teams, the message is that size is not a defence: TPR expects proportionate but credible governance, clear decision trails and demonstrable member focus. Firms should use the findings as a diagnostic: review trustee composition and training, challenge adviser reliance, test internal controls and cyber/data oversight, and document how member interests are protected.

Smaller schemes should consider whether professional trustees, shared governance arrangements or consolidation offer a more sustainable model. Sponsoring employers and advisers should also reassess governance support and reporting. The release is not a new rule, but it signals supervisory emphasis and raises the risk of engagement for schemes unable to evidence good governance.

Near-term actions should include a gap assessment, an action plan with owners and dates, and board/trustee reporting. Commercial opportunities exist for governance specialists, professional trustees, consolidation providers and RegTech tools that improve trustee oversight and evidence.