The Pensions Regulator (TPR) has today published its AI Plan setting out initial expectations for how trustees should govern the use of artificial intelligence (AI).
AI has transformative potential to improve administration, decision‑making and member engagement in pensions. But TPR is clear that accountability for outcomes remains with trustees and scheme managers, regardless of whether decisions are supported by AI systems.
Alongside its expectations, TPR has signalled forthcoming plans for detailed guidance to be published later in the year with a call for industry to engage over the summer.
And as pension schemes increasingly adopt AI technologies, the regulator has provided further clarity on its own next steps to safeguard members, support responsible adoption and enable innovation in pensions.
As part of this, TPR will continue to use AI and advanced analytics within its regulatory work to better identify risks, target scams and protect savers, including the analysis and takedown of high‑risk scam websites.
Nausicaa Delfas, Chief Executive of TPR, said:
“AI has the potential to transform pensions for the better: improving how schemes are run, how members are supported, and how the system as a whole delivers value.
“But trust is the most valuable asset in our system, and that trust depends on the safe and responsible adoption of AI in members’ interests.
“Our message to trustees, administrators and scheme managers is clear: act now. Put strong governance in place, invest in data quality, understand where and how AI is being used in your scheme, and protect your members from AI-driven fraud.”
Expectations of trustees and scheme managers
Trustees and scheme managers remain accountable for outcomes even when activities are delegated. More detail on good practice will be set out in forthcoming guidance, but in the meantime TPR expects schemes to:
- Establish clear governance for AI use, including assuring themselves that administrators, service providers and advisers have similarly robust arrangements in place.
- Carry out rigorous testing, assurance and ongoing monitoring of AI systems
- Identify and evaluate risks, with appropriate controls reviewed regularly and adapted as necessary.
- Prevent members being scammed by being aware of AI-driven fraud methods and responding effectively to the evolving threat.
- Have a clear data strategy, ensure scheme and member data is of high quality, and comply with data protection legislation – including as it relates to automated decision-making.
- Seek professional advice, appropriately and proportionately, when considering or implementing innovations.
Next steps for TPR
The plan sets out four areas of focus for the Regulator to enable the safe adoption of AI:
- Ensuring all schemes are well run and well governed, including working with the FCA to ensure regulatory alignment across the pensions sector and supply chain.
- Putting the data building blocks in place, including continued engagement with schemes on data and ensuring our online content is high quality, machine readable and easily ingested by AI models.
- Supporting and fostering responsible innovation, including through TPR’s innovation service.
- Harnessing AI to become a more effective regulator, building on the successful use of an AI-enabled process to tackle pension scam websites, which has assessed over 2,000 sites and enabled the removal of 29 high-risk sites.
TPR will report annually on progress and will continue to evolve the plan as the pensions landscape changes.
