Following engagement with hundreds of schemes of all sizes, The Pensions Regulator (TPR) is calling on trustees to treat member data as their most important 'strategic asset'.
A large scale TPR engagement exercise has revealed significant progresshas been made to improve data quality in preparations for pensions dashboards. But TPR’s report shows that some schemes still have more to do to get their member data in shape to be ready for pensions dashboards in less than a year’s time.
Key findings from the regulatory initiative were:
• While most schemes have made progress on cleansing personal data for dashboards, value data – used to calculate benefits – is often overlooked. Improvement plans are frequently informal or fragmented, and trustee engagement ranges from proactive oversight to near-complete reliance on administrators.
• Controls and trustee focus vary widely. In many cases, administrators lead data assessments with limited trustee scrutiny. Whilst data issues are being addressed by some schemes, an historical underinvestment in data management by others means the industry faces a ‘data debt’. TPR research published in July found that one in four schemes still hold some non-digitised records. And fewer than three in five schemes are confident in the accuracy of the common data they hold on their membership.
• The regulatory initiative (RI) exercise focused on measuring data and putting improvement plans in place – a necessary foundation for schemes preparing to connect to the pensions dashboard. The regulator is intensifying its engagement with the industry as part of its ongoing work in this space.
TPR’s Executive Director of Market Oversight, Julian Lyne, said: “Good data is the foundation of good governance and a trustee’s most important strategic asset. Trustees are accountable for ensuring member data is correct – no-one else. Maintaining its quality is an ongoing responsibility, because neglect can be costly and have real-world consequences for savers. With the pensions dashboard deadline less than a year away, the need for reliable data has never been more urgent. The gaps identified in our report risk undermining dashboard readiness and highlight the importance of trustees adopting robust, consistent practices across all aspects of data management. Good data must be complete, accurate, timely, consistent, unique, valid and properly managed.”
New guidance to help treat data as a strategic asset
Following its findings, TPR has today published revised member data guidance that consolidates all data-related guidance into one place and sets out clearer expectations and provides best practice examples to help schemes achieve better data management capability. The guidance explains how:
• Trustees are ultimately accountable for data quality, even if tasks are delegated to administrators.
• They must ensure regular data assessments, review reports, and submit accurate data scores in their scheme return.
• Trustees should have a clear data management strategy, allocate resources for improvements, and challenge service providers where standards are not met.
• The regulator is now scrutinising the data preparations of the UK’s largest schemes and will expand its engagement in 2026.
Trustees need to be ready to demonstrate how they are maintaining data, in line with legal requirements and TPR expectations. Schemes unable to demonstrate compliance may face formal intervention, including improvement notices.
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