AI Plan issued by The Pensions Regulator – what does it mean for pension trustees?

This week, The Pensions Regulator (TPR) has issued its "AI Plan" – the first major step taken by TPR to set out how it expects trustees to approach using AI. 

We recommend all pension trustees read the Plan. 

What does the Plan cover?

TPR sets out:

1. How it views its role and approach to "supporting the use of AI in pensions",
2. Its expectations of trustees, administrators and scheme managers,
3. The steps that it "will take to enable safe AI adoption [and] innovation" in pensions, and
4. How TPR "will harness AI". 

What is new about the Plan?

TPR has previously commented on how it is using AI (such as in its "Digital, Data and Technology Strategy" back in October 2024), so the messaging around expectations of trustees and enabling AI adoption in the industry is the major development from the AI Plan. 

Key extracts 

Some key extracts from the AI Plan include:

• "[Trustees] need to understand where and how AI is being used by or on behalf of their pension scheme."
• “AI adoption and innovation must be safe and in the interests of members”
• "We expect trustees and scheme managers to... establish clear governance and accountability for the use of AI systems and technologies [and] work to prevent their members being scammed by being aware of AI-driven fraud methods and responding effectively to the evolving fraud threat [and] understand how AI models use and process data and ensuring there are robust controls in place."
• "We expect trustees, scheme managers and administrators to seek appropriate and proportional professional advice when considering or implementing innovations."

TPR’s role and next steps

TPR states that it has a responsibility to ensure that AI adoption is safe and benefits members by, amongst other things, (a) “ensuring all schemes are well run and well governed”, and (b) supporting and enabling AI adoption and innovation. 

TPR also states that it will be publishing guidance “on the responsible adoption of AI for pension schemes” in 2026 – so be on the look out for that. 

What we have been seeing

We look forward to seeing how TPR further addresses AI in the industry over the coming months, in particular via the trailed guidance. For now, we recommend trustees continue to consider:

• Undertaking training on AI opportunities, risks and risk mitigation measures,
• Reviewing and updating their governance framework in light of AI (e.g. adopting an AI policy),
• Implementing mitigations in respect of AI risk (in particular, by including warnings to members in scheme communications about the hazards of using AI to understand pension information or to make financial / retirement decisions), and
• Engaging with their service providers about how they are using AI.

The interaction between AI and Pensions is a topic we are seeing lots of our clients be very interested in. If you are interested in discussing how AI might impact you, please contact  Chris Brown, Partner or Callum Duckmanton, Solicitor, both in the Pensions and Lifetime Savings Team at Burges Salmon.  To hear more of what we are seeing in the industry, you can listen to our podcast episode on the topic here or our guest appearance on “Pensions and AI”, here.

This article was written by Callum Duckmanton and Chris Brown. 

Artificial intelligence (AI) technologies have the potential to transform the pensions system and deliver better outcomes for millions of workplace pensions members.

https://www.thepensionsregulator.gov.uk/document-library/corporate-information/ai-plan