AI has the potential to transform the pensions industry by improving efficiency, value for money and member outcomes, but can also introduce new risks including around cyber security.
AI use is growing across financial services and pension schemes. Research this year found 86% of respondent financial services firms reported currently using AI, up from 75% in 2024. In pensions, an Aon survey of 61 UK defined benefit pension schemes found 76% reported some use of AI by trustees.
While trustees do not need to be AI experts, TPR is clear that trustees need to understand enough to ask the right questions and challenge its use effectively.
The guidance sets out seven key principles for trustees and scheme managers, which mirror how TPR itself uses AI as a regulator:
Start with the problem, not the technology
Human responsibility remains central
Governance is ongoing, not one-off
Plan for disruption
Good AI starts with good data
Transparency and explainability underpin trust
Support fair and accessible outcomes
Ben Gunnee, TPR's Executive Director of Market Oversight, said: “AI has the potential to improve efficiency, value for money and member outcomes and cannot be ignored. Trustees should responsibly embrace the opportunities on offer.
“Trustees don’t need to be AI experts, but they are accountable. They must always know where it is used, ask the right questions to challenge providers, and manage risks that any new technology presents.”
TPR's guidance helps trustees understand how their existing duties and good governance apply to using AI, rather than creating a separate set of regulatory requirements. Trustees remain responsible for decisions affecting schemes and members and should understand where significant AI is being used and ensure appropriate governance and oversight are in place.
The TPR convened data and digital industry working group has also developed an AI jargon buster to help trustees understand AI terminology and support conversations with providers and advisers.
Read TPR's AI Guidance
TPR published an AI action plan in May 2026 setting out how it would the regulator would use AI to safeguard members, support responsible adoption and enable innovation in pensions. As part of this, TPR uses AI and advanced analytics within its regulatory work to better identify risks, target scams and protect savers, including the analysis and takedown of high risk scam websites.
The latest joint Bank of England and Financial Conduct Authority survey of artificial intelligence in UK financial services found 86% of respondents reported using AI, up from 75% in 2024. Third-party implementations accounted for 39% of reported AI systems. Source: Bank of England and FCA: Artificial intelligence in UK financial services 2026
An Aon survey of 61 UK defined benefit pension schemes found 76% reported some use of AI by trustees. It also found 61% did not know how their advisers use AI and 73% carried out no specific assessment of their providers’ AI governance. Source: Aon: Three quarters of pension trustees using AI
TPR’s guidance complements FCA: AI in financial services: good practice and areas for improvement but has a different, pensions-specific purpose. While the FCA sets out good and poor practice for regulated firms using AI, TPR’s guidance helps trustees and scheme managers understand how their existing duties apply to AI, including how they oversee its use by pension providers. Both support responsible innovation, strong governance and good outcomes within their respective regulatory remits
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