Earlier this year, we reported on The Pensions Regulator’s (TPR) evolving regulatory strategy and its shift towards a more prudential style of regulation. Now, with the launch of its Enforcement Strategy Consultation, TPR has brought this transformation into sharper focus, setting out a new approach that aims to be more agile, targeted and outcome driven.
As the pensions landscape continues to grow in complexity, with rising expectations and serious consequences when things go wrong, TPR is seeking to reshape its enforcement strategy to act earlier, respond more effectively and deliver better outcomes for savers against serious risks. This marks a deliberate move away from reactive enforcement towards smarter, collaborative, risk-based regulation.
What’s Changing?
Although the current strategy has delivered important enforcement outcomes, the proposed new strategy is set to introduce several changes designed to make enforcement more strategic and impactful. It is designed to:
- Strengthen alignment with its statutory objectives and corporate priorities;
- Utilise a full range of regulatory tools from communications and direct engagement to formal enforcement action; and
- Prioritise preventing harm before it arises, while remaining prepared to escalate stronger action when required.
Overall, the strategy’s aim is to introduce a more targeted and responsive model that reflects the changing risks across the pensions and wider regulatory landscape. It seeks to place savers’ outcomes at the forefront by establishing clear enforcement priorities, focusing on issues that pose the greatest risk to savers and the integrity of the pensions system. TPR has said that the aim is to concentrate resources on the most serious harm and intervene earlier to prevent escalation. This will require closer integration between TPR’s Enforcement and Market Oversight teams and the strengthening of partnerships with external partners to deliver coordinated enforcement outcomes.
TPR has also indicated that digital tools are to play a key role in identifying trends, guiding decisions and tracking results. It says that transparency around enforcement outcomes and communicating expectations will also be prioritised, with the aim of building trust across the industry, with the view of ultimately raising standards and accountability.
What you need to know:
For trustees and employers, the new strategy sets an expectation that governance will be robust and risks actively managed and prevented. Engagement with TPR at an early stage will be key and schemes that fail to demonstrate good governance or compliance may face earlier more targeted interventions. This approach reflects TPR’s move towards smarter, risk-based regulation, with a focus on preventing harm before it escalates.
With the increased collaborative model, advisers should support schemes in identifying and addressing risks early on, before matters escalate, helping those avoid regulatory breaches and enforcement action.
Importantly, TPR has announced that the adoption of the new strategy will prompt a review of its wider suite of enforcement policies and procedures, stating that this may involve consolidating areas where there may be overlap and updating current guidance to ensure alignment with the new strategic direction.
This is important to keep on your radar. Whilst the current enforcement strategy, policies and procedures remain in force and continue to guide TPR’s work, change may be on the horizon.
The Consultation
The consultation presents a valuable opportunity to help shape how TPR exercises its powers and prioritises enforcement in the years ahead. TPR is actively encouraging people to read the proposed strategy, share their views, and contribute to meaningful change across the industry, welcoming responses from everyone “whether you’re a trustee, employer, adviser or simply someone who cares about the future of pensions”.
The consultation window closes on 11 November 2025, so now is the opportunity to influence how enforcement evolves. TPR has indicated that summary of consultation responses and final strategy will be shared in early 2026, with a full review the policies to follow later, noting that any necessary changes may be subject to further consultation
If you would like to discuss any of the issues raised in this blog, please contact a member of the pensions team or your usual Brodies contact.
