DWP’s Trusteeship Consultation: key themes and industry responses

The Department for Work and Pensions (DWP) recently closed its consultation “Trust-based pension schemes: Trustees and governance – building a stronger future”. The consultation considered how standards of trusteeship, governance and administration across trust-based pension schemes can continue to evolve in light of a changing pensions landscape, increasing regulatory complexity and ongoing market consolidation.

The consultation ran from 15 December 2025 to 5 March 2026. It built on earlier work, including the 2023 call for evidence on trusteeship standards, and forms part of a broader programme of reform affecting trust-based pension schemes.

Industry responses to the consultation have generally been constructive. The Pensions Management Institute (PMI) has said that it “welcomes the [DWP’s consultation] as a timely and necessary intervention in a rapidly evolving pensions landscape” and it “strongly support[s] the Government’s ambition to raise standards of trusteeship, governance, and administration across all trust‑based pension schemes”. The Association of British Insurers (ABI) commented that “it is right that DWP and [the Pensions Regulator] are exploring improving the standards and consistency of trusteeship in the pensions system”. Pensions UK similarly notes that “[r]eform should build on existing foundations, recognising the need for innovation and that schemes should be given the flexibility to trial new approaches”.

The consultation was structured around five broad themes, each of which is summarised below.

Good Governance

The consultation explored how trustee boards can continue to meet rising governance expectations, particularly as pension scheme decision‑making becomes more complex and multifaceted.

The consultation recognised that ongoing consolidation in the pensions market is likely to result in fewer, larger schemes over time, alongside greater use of professional trustees. Evidence suggests that different governance models and scheme structures can influence how governance is delivered in practice, and the consultation therefore considered how all trustees can be supported to operate in an environment conducive to effective decision‑making, regardless of scheme size or structure.

In this context, the DWP highlighted a range of system wide considerations, including the management of conflicts of interest (particularly where trustees operate across multiple schemes or in commercial contexts) and the governance implications of trustee appointment and removal processes, especially where scheme funders play a role. 

The ABI have commented that “higher expectations of trustees, especially professional trustees, delivered by standards of accreditation, clarity on professionalism and qualifications relevant to the duties, are the right direction of travel”.

Trustees and their appointment

The consultation examined current practices around trustee appointment, the barriers that may affect effective trusteeship, and how both lay and professional trustees can be better supported in meeting their responsibilities.

The DWP noted that trustees operate across a wide spectrum of schemes with differing levels of complexity, funding and resources. In that context, the consultation raised the question of how to ensure that all trustees have appropriate awareness of the scope of their duties and access to proportionate support to carry them out effectively. It also recognised that an increasing number of trustees now hold multiple appointments, which may give rise to more complex conflict management considerations over time. 

One proposal on which the DWP sought views was the potential introduction of a statutory “public trustee” role for distressed or orphan schemes, drawing on approaches used in some other jurisdictions. As described in the consultation, such a role, appointed by the Pensions Regulator (TPR), could provide an independent option to help ensure continuity of administration and protection of members’ interests where a scheme faces particular challenges.

Skills and knowledge

Acknowledging the growing technical and regulatory demands placed on trustees, the consultation considered whether existing requirements around trustee knowledge and understanding remain appropriate.

Areas explored include the potential introduction of mandatory accreditation for professional trustees, with the aim of establishing a consistent baseline of competence and ongoing professional development. The consultation also considered whether expectations for all trustees could be refined or expanded to reflect the breadth of skills now required, including governance, oversight and decision‑making capabilities, in addition to technical knowledge.

In parallel, the DWP sought views on how support for lay trustees could be made more accessible, for example through centralised resources that clearly signpost guidance, training and regulatory materials.

The Association of Consulting Actuaries (ACA) commented that “it is the trustee board as a whole that needs to have the appropriate skills. If overall skill requirements were applied at the individual trustee level, this is likely to have a detrimental impact on recruitment of new lay trustees and diversity”.

Member voice

The consultation considered how trustee boards ensure that members’ views are appropriately considered when making decisions that affect retirement outcomes.

The DWP recognised that different governance models adopt different mechanisms for member engagement, and that this issue may arise in particular where schemes are governed by professional or corporate trustee structures. Views were therefore sought on how trustee boards can continue to reflect a broad range of member perspectives in decision‑making, regardless of scheme size or governance arrangements.

Administration

The DWP identified variation in administration standards across the pensions landscape and considered whether changes to the regulatory framework might support greater consistency.

Options explored included expanding TPR’s powers to set scheme‑level administration standards, or introducing more direct regulation of pension scheme administrators. The consultation also notes ongoing challenges around data quality and the degree of digitisation across schemes.

More broadly, the DWP highlighted market concentration risks, including the potential impact on members and schemes if a large administrator were to exit the market in a disorderly manner.

The Pensions Administration Standards Association (PASA) commented that “The consultation recognises the strategic and operational importance of high quality administration within a well governed trust‑based system” and calls for “mandatory, proportionate minimum administration standards grounded in existing, industry-tested frameworks”.

Five key takeaways from the consultation

Based on the themes explored in the consultation, the following points may be of interest to trustees and advisers:

1. Governance expectations are continuing to evolve and increase across all trust‑based schemes.
2. Mandatory accreditation for professional trustees is under consideration.
3. Corporate and professional trustee models may attract increased regulatory focus.
4. Trustee appointment and removal processes may be subject to additional safeguards.

5. Regulation of administrators and minimum administration standards are being considered.

Burges Salmon comment

Overall, the consultation highlights a continued focus on strengthening governance and administration across trust‑based schemes in a changing pensions landscape. While responses have broadly supported the direction of travel, many have stressed the importance of proportionality and building on existing frameworks. The DWP’s next steps are likely to involve further engagement with industry and TPR as it considers whether, and how, these proposals should be taken forward through legislation, regulation or guidance.

If you have any questions please do get in touch with Susannah Young or your usual Burges Salmon contact.

Article written by Sinead O’Donoghue and Matthew Pegler