Executive Summary

The Pensions Management Institute (PMI) welcomes the Department for Work and Pensions’ (DWP) consultation on “Trust-based pension schemes: trustees and governance – building a stronger future” as a timely and necessary intervention in a rapidly evolving pensions landscape.

The PMI is the UK’s leading professional body for pensions professionals and trustees, representing over 8,500 members responsible for managing and advising some of the world’s largest pension schemes. As such, we strongly support the Government’s ambition to raise standards of trusteeship, governance, and administration across all trust-based pension schemes, recognising the pivotal role trustees and administrators play in safeguarding the retirement outcomes of over 40 million UK savers.

Trusteeship is a precious public good within the UK pensions system. The model delivers independent judgement, fiduciary discipline, and a direct focus on member outcomes that is not replicated in contract-based arrangements. The PMI believes that trusteeship should be protected, strengthened, and - where appropriate - extended so that all savers benefit from decisionmakers whose sole purpose is to act in their best interests.

We are not starting from scratch. The sector has already taken major steps to raise standards and develop accreditation frameworks for both trustees and administrators. But the world is changing rapidly, and increasing complexity means that individuals making decisions on behalf of millions of savers must meet high - and rising - expectations. Any system of trustee and administration standards must therefore be meaningful, enforceable, and equipped with real disciplinary “teeth” where individuals or firms fall short.

The PMI strongly endorses the regulatory ratification of an agreed set of standards for trustee knowledge and understanding, the mandating of professional trustee accreditation and the extension of regulatory oversight and accreditation to scheme administration. However, we emphasise that all new requirements must be proportionate to scheme size, complexity, and resources, ensuring that smaller schemes, lay trustees and smaller administrators are not unduly burdened or excluded from the governance landscape whilst systemically significant schemes (e.g. DC megafunds, DBSFs) are held to higher standards overtime.

The PMI is committed to supporting both professional and lay trustees as well as administrators through our qualifications, accreditation, and continuing professional development (CPD) programmes, and we stand ready to collaborate with DWP, The Pensions Regulator (TPR), and sector partners to deliver practical, effective reforms.

Our response is structured by consultation chapter and question, and we draw on our extensive experience as the UK’s leading professional body for pensions professionals, our role in trustee accreditation, and our evidence from member engagement, training delivery, and international best practice.

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