The Government is particularly interested in hearing from trustees on matters including: increasing trustee knowledge and understanding, standards for professional trustees, improving the diversity of trustee boards, and keeping the member perspective as schemes consolidate. The consultation closes on 6 March 2026.
A changing pensions landscape
New options for DB schemes, including surplus release and end game solutions, are increasing demands on trustees. The Value for Money framework and new responsibilities to offer retirement solutions to DC members are expected to accelerate the move towards fewer, bigger DC schemes.
The Government anticipates that consolidation in both markets will lead to a move away from traditional trustee boards overseeing smaller schemes, but professionalisation of trusteeship brings a risk of new conflicts of interest.
We summarise below the main questions asked of trustees across the five chapters of the consultation. There are 27 questions in total.
Good governance
The Government believes that there should be more stringent standards on trustees' technical knowledge and understanding in the new environment. It wants to hear from trustees on what is working well in the current system and - looking to the changes coming over the next five years - what further support they need to ensure effective governance.
With professional trustees concentrated in a relatively small number of firms, many of which provide other services, the Government is seeking views on conflicts of interest, whether there should be restrictions on the number of appointments, and the suitability of Professional Corporate Sole Trustee arrangements in different circumstances.
Trustees and their appointment
The Government believes that it will become more important for diverse and inclusive trustee bodies with a wide range of skills, to ensure good decision-making as schemes grow in size. It asks for views on controls and safeguards on appointment, the role government and regulators can play in attracting diverse and talented individuals to trusteeship, and whether there should be any limits on how long someone can be a trustee of the same scheme.
When The Pensions Regulator wants to use its power to replace a trustee, it can do so only from a small number of professional trustee firms on its register. The Government is seeking views on whether these powers might be modified, including by establishing a new public trustee as an available alternative.
The Government plans to work with The Pensions Regulator on establishing a complete directory of trustees — not for publication — and seeks views on how this can be done without increasing the administrative burden on schemes or trustees.
Skills and knowledge
The Government is seeking views on skills that trustee boards will need in the new environment, continuing professional development and/or accreditation for lay trustees, and whether it would be appropriate to set higher, statutory standards for professional trustees. It also wants to explore how consolidated schemes could continue to achieve the benefits that lay trustees bring in the existing model.
Member voice
The move towards fewer, larger DB and DC multi-employer schemes will change the role of traditional member nominated trustees. The Government believes that it is important that the voices of members are still represented in a more consolidated market and would welcome views on how this can be achieved.
Administration
Trustees oversee their administrators, but don't have day-to-day involvement. There is voluntary accreditation for administrators but no statutory standards. The Pensions Regulator does not regulate administrators and is concerned about what would happen if one of the big third-party administration providers were to fail. The Government is seeking views on whether there should be mandatory minimum standards and registration of administrators with The Pensions Regulator.
Comment
This wide-ranging consultation asks important and open questions. It is more of a call for evidence on trusteeship than a detailed set of proposals, and is a good opportunity for trustees to have input into the direction of future policy on trust-based scheme governance in all its forms.
