According to Lumerathe roadmap highlights both the speed and scale of change required across the pensions industry, giving providers and trustees a clear view of when they need to be ready for reforms that will fundamentally change how disengaged members are supported.
The data has consistently shown that consumer engagement with pensions remains low.
DWP research on DC pension decumulation released ahead of the roadmap, found that most of the respondents - aged 53-67 - understood that DC pots were invested but only a few actively engaged with investment decisions. Knowledge of products, fees and investment risk was generally low, with many struggling to differentiate between access routes or assess long-term implications.
Separate DWP analysis found that three quarters (77%) of DC pension holders aged 40-75, yet to access their pension, did not have a clear plan on how to do this, and a fifth (21%) were not even aware they had to make a choice.
This has driven a significant change in policy direction, with reforms increasingly focused on ensuring better outcomes for members who are unlikely to make active decisions about their retirement.
While it represents a new and overdue focus for pensions policy, it also creates entirely new challenges for delivery. A key example of this is Guided Retirement, which will see disengaged members assigned to default retirement options that are assessed to be the most suitable for them.
It means decision makers, such as trustees, will need to use the data they hold on their members, which is usually quite limited, to justify why a member is placed on a specific pathway. This means the industry will need to develop new approaches to governance, data management and technology-enabled decision making to ensure decisions are robust, transparent and made in members’ best interests.
This is one of the areas where the use of AI may come to be seen as a necessity to evidence that the best approaches available are being used to translate this limited member data into justifiable assignments to default pathways, and to update the approaches based on future data on how these members actually behave as they transition into retirement.
The new timeframe for Guided Retirement to be introduced in 2029 not only allows for the development of a robust regulatory framework for this reform, but also enables time for the establishment of regulatory guidance around the use of AI to support it.
While the Pensions Act 2026 introduced Guided Retirement in the trust-based market, the updated roadmap confirms that the FCA will also produce a discussion paper on implementing an equivalent approach for contract-based pensions, potentially further expanding its scope across the sector.
Maurice Titley, Commercial Director, Data & Dashboards at Lumera, commented: "The DWP’s updated roadmap provides a clearer path for DC pension reform, giving providers and trustees greater visibility on when they need to be ready for some of the biggest changes the industry has seen in recent times.
“This next phase of reform will require providers and trustees to make increasingly complex decisions on behalf of members at scale. New initiatives like Guided Retirement will therefore be a tough test of the industry’s ability to manage data and implement strong governance frameworks that can deliver for their members.
“Providers will need to demonstrate that default pathways are being designed and allocated using the best available information to maintain trust, with AI set to play an important role in helping schemes make more informed decisions on behalf of their members.
“This updated roadmap starts the clock for providers and trustees. The priority now is to build the data capabilities, technology infrastructure and system processes that are required to deliver these reforms effectively.”
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