The paper, titled Governance in the Age of AI: A Practical Framework for Responsible Leadership, emphasises that while AI adoption has rapidly accelerated, trustees' core fiduciary duties remain unchanged.
Scheme leaders are urged to adapt existing governance, data security, and risk frameworks to oversee AI's growing influence on scheme administration, investment strategies, and member communications.
Key Principles for Responsible AI Leadership
The SPP framework outlines five core principles for schemes navigating AI integration:
Proportionality to Risk: Classifying AI usage into low, medium, and high-risk tiers. High-risk uses (such as outputs directly affecting member benefits or advice) require enhanced governance and robust validation.
Meaningful Human Oversight: Ensuring automated decision-making (ADM) involves qualified human reviewers who hold real authority to evaluate and alter outcomes.
Data Security & Privacy: Guarding against data breaches by ensuring confidential scheme information or sensitive personal data is never inputted into unapproved or public AI models.
Third-Party & Adviser Governance: Updating supplier contracts to mandate transparency around AI tools, human review policies, and protection against AI-enabled cyber fraud or deepfakes.
Member Guidance: Providing clear scheme communications to prevent members from relying on inaccurate or hallucinated guidance from public AI tools.
The SPP stresses that AI governance is not a separate discipline but an essential component of fulfilling fiduciary responsibilities under existing regulatory standards. By embedding these controls into risk registers and service reviews today, trustee boards can confidently harness AI's efficiencies while protecting member interests
Jo Fellowes, Chair of the SPP Administration Committee said: "Artificial Intelligence has moved from an emerging technology to an everyday reality across the pensions industry. The challenge is therefore not whether AI should be used, but how it can be used safely, transparently and with appropriate oversight. This SPP guide should help schemes achieve this"
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