TPT calls for stronger safeguards to protect members in response to DWP trusteeship consultation
TPT has today submitted its response to the Department for Work and Pensions’ (DWP) consultation on trusteeship, urging policymakers to consider stronger safeguards that ultimately protect trustee independence and keep member outcomes front of mind at all times.
With government policy accelerating scheme consolidation, TPT warns that governance frameworks must evolve to match such scale, complexity and emerging risks that come with this – particularly with the creation of larger, and often commercially-owned, ‘megafunds’.
TPT supports a balanced approach to reform, recognising the vital contribution of the expertise brought by professional trustees while emphasising the continued importance of the member voice.
However, TPT cautions that growing commercial pressures within the professional trustee market risk undermining independence. Private equity ownership structures, cross-selling bundled services, adviser-trustee dependencies and restrictive tendering practices are increasingly prevalent.
Because of this, TPT is calling for clearer regulatory controls, including restrictions on self-appointment, requirements for independent tender processes and limits on bundled commercial arrangements.
The leading workplace pension provider also highlights the need for greater scrutiny of the wider governance ecosystem, particularly the largely unregulated adviser and consultancy market, given the close commercial dynamics between advisers and trustee firms.
At the same time, TPT emphasises that any reforms should carefully preserve the distinctive contribution that lay trustees make to pension scheme governance. Lay trustees often bring a breadth of professional and lived experience, and a closer understanding of the employer and membership, which can be difficult to achieve in certain structures, e.g. master trusts.
As schemes consolidate it will be important to ensure these qualities are not lost. Member panels and other channels to facilitate member and employer representation will need to take an increasing role to ensure a balanced and informed approach is taken to decision-making.
TPT notes that the rise of megafunds will heighten systemic and conflict risks. Trustee independence from scheme funders will become increasingly important, alongside stronger technical capability and clearer mechanisms for embedding member perspectives in decision-making.
Ruari Grant, Head of Policy at TPT Retirement Solutions, said:
“Trusteeship is one of our longest standing and effective governance models, and this consultation addresses the key evolutions in the market to make sure it remains the model that scheme members can have faith in. Consolidation has the potential to strengthen outcomes for savers, but it also increases the importance of robust and independent governance, as well as the expertise to manage ever larger and more complex strategies.
As schemes grow, and as those providing trusteeship move from an independent, non-profit basis to a more commercial one, policymakers must ensure the right safeguards are in place to make sure trustees are able to act in the best interests of their members, without influence from either commercial providers or trustee firms.”
TPT looks forward to continuing to engage with DWP as the consultation process progresses.
Notes to Editors
TPT Retirement Solutions (TPT) is one of the UK’s leading providers of workplace pensions with 80 years’ experience of managing defined benefit and defined contribution pension schemes. It has £11.4 billion of assets under management (as at 30 September 2025) and more than 490,000 members.
TPT’s mission is to make pension schemes perform better for everyone, from the sponsoring employers and trustees to the members who are saving for the future. It is an innovative, forward-thinking organisation, investing in technology to improve the services they provide. TPT is ultimately owned by a pension fund, providing genuine alignment of interests with those of its clients and scheme members.
Our ownership
TPT Retirement Solutions Limited is wholly owned by Verity Trustees Limited in its capacity as trustee of The Pensions Trust.
TPT Investment Management Limited is a wholly owned subsidiary of TPT Retirement Solutions Limited.
Group Services & Regulation
Verity Trustees Limited is the corporate trustee of The Pensions Trust and The Pensions Trust 2016. It is a company limited by guarantee and is regulated by The Pensions Regulator. Registered in England and Wales under company number 00744017. Registered office: 5th Floor 3 South Brook Street, Leeds, England, LS10 1FT.
TPT Retirement Solutions Limited provides pension management and administration services to UK pension schemes. Registered in England and Wales under company number 09639961. Registered office: 5th Floor 3 South Brook Street, Leeds, England, LS10 1FT.
TPT Investment Management Limited is authorised and regulated by the Financial Conduct Authority (FCA) and provides investment management and consultancy services to UK pension schemes. Registered in England and Wales under company number 14527587. Registered office: 5th Floor 3 South Brook Street, Leeds, England, LS10 1FT.
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