Pensions - Articles - Comments on TPRs report on use of AI in workplace pensions


Hymans Robertson and Lumera comment on The Pensions Regulator (TPR) AI plan on setting out initial expectations for how trustees should govern the use of artificial intelligence (AI). Focusing on the importance of a clear data strategy, ensuring scheme and member data is of high quality and complying with data protection legislation – including as it relates to automated decision-making.

Scott Finnie, Head of Digital Strategy, Hymans Robertson, said: “We’re pleased to see TPR providing guidance on AI and support the principles outlined. AI brings significant opportunity for better member outcomes whilst simultaneously opening up new risk vectors. Navigating the fast-moving landscape will require diligence, adaptation and strong collaboration among Trustees, their industry partners and the regulator. An agreed ethical framework will aid trustees in the series of decisions they will need to make with the use of this developing technology. It’s encouraging to see that TPR has highlighted the importance of data quality as a pre-requisite to positive AI-enabled outcomes. GMP equalisation, Risk Transfer, the Pensions Dashboard and AI are all motivating an industry wide move from data that is “mostly right, most of the time” towards data that is “all right, all of the time”. Getting there will require sustained commitment across the industry but doing so will enable better outcomes for members and aid Trustees more generally in fulfilling their responsibilities.”

Maurice Titley, Commercial Director: Data & Dashboards at Lumera, commented: “The Regulator’s AI plan, and their intention to publish more detailed guidance in 2026, is an important step in setting clear expectations for how AI should be deployed responsibly across the pensions industry.Their approach of engaging with industry is welcome as there are many areas where AI innovation is being considered, not least in response to some of the new demands that will flow from reforms in the Pensions Act, such as assigning members to default retirement pathways. As we enter a new era for the pensions sector in the UK, AI is set to be a critical driver of transformation in how providers achieve greater efficiencies, strengthen governance and improve the member experience. The Regulator is right to point out that AI will bring both opportunities and risks which will require the industry to centralise innovative operating models, human oversight and robust governance to achieve the confidence of trustees. Scalable technology and a clear data strategy will be essential in ensuring that automated decision making is working off accurate records to achieve good outcomes for members. With these data building blocks in base, providers will have the potential to improve administration, standards and outcomes right across the pensions sector, enhancing rather than replacing the expertise that defines the industry.”

TPR clarifies responsible use of AI in workplace pensions

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