Lessons from the first wave of Own Risk Assessments in the UK

The first wave of Own Risk Assessments (ORAs) marks an important turning point for trustee boards. As schemes with 31 March 2026 scheme year ends complete their first ORAs, attention is shifting from preparation to reflection: what has the process revealed in practice, and what does it tell us about the strengths, limits and future direction of scheme governance frameworks?

A snapshot, not an end point

For many schemes, the ORA has drawn together several years of work undertaken to align governance arrangements with the Pensions Regulator's General Code. While approaches have inevitably varied, the first completed ORAs are starting to highlight a number of common themes that shed light on how the requirement is operating in practice.

Across the first wave, ORAs have often followed an extended period of policy development and governance gap‑filling. Against that backdrop, the initial ORA has generally functioned as a snapshot of arrangements at a particular point, rather than a declaration that systems and processes are fully complete.

The vast majority of completed ORAs, as they should, document areas where governance frameworks are operating effectively alongside areas where further development is planned. This reflects the ORA's purpose as an assessment of effectiveness at that point and meets a stated hope from TPR of the application of a continuous improvement mindset, rather than an assertion of full or final compliance. In that sense, the first ORA has frequently served to formalise ongoing improvement activity and to provide a clear baseline for future assessment.

Proportionality required judgement

The first wave of ORAs has brought the concept of proportionality into sharper focus. Completing an ORA has required trustee boards to make explicit judgements not only about scope, but also about the depth of assessment and the level of evidence needed to support conclusions. So, proportionality has rightly been applied to the process followed, not just the nature of report write-up.

In some areas, ORAs have drawn on existing monitoring and assurance processes, such as adviser reporting or established oversight frameworks. In others, the exercise has highlighted reliance on informal practices or legacy arrangements, prompting consideration of whether more structured documentation or oversight would provide greater assurance going forward.

Taken together, the experience of the first wave suggests that proportionality is less about volume and more about the ability to demonstrate reasoned, scheme‑specific judgement.

Value lay in stepping back

The ORA process has been most informative and most valuable where it goes beyond simple collation and creates space to step back from the detail of day-to-day governance and matters at hand. In these cases, it has facilitated a more holistic appraisal of governance and risk management arrangements.

This has included consideration of how individual risks interact, whether controls remain aligned to scheme objectives, and how effectively risk information is integrated into board‑level decision‑making. In some instances, there have been refinements to risk registers, clearer articulation of risk appetite, or changes to how and when risks are discussed during the year.

By contrast, where the ORA has been treated primarily as a compilation exercise, these broader insights have been less apparent.

Clearer differences in governance maturity

One consequence of completion of the first wave of ORAs has been greater visibility of differences in governance maturity across topics. Areas with long‑established regulatory focus, such as investment governance or funding oversight, are often supported by well‑embedded processes, clear documentation and assurance frameworks.

By contrast, other areas, including operational resilience, cyber risk, data and succession planning, have more often been characterised by evolving practices rather than settled frameworks. In many ORAs, these topics have been accompanied by forward‑looking actions, indicating that approaches are still developing, rather than fully evidenced conclusions of effectiveness.

Board effectiveness reviews have also emerged as an area where approaches continue to develop, with some trustee boards identifying scope to strengthen how performance, skills and succession planning are assessed and evidenced.

This differentiation has helped inform prioritisation, enabling trustee boards to focus development activity where governance frameworks are less mature, rather than progressing all areas at the same pace.

The first ORA is shaping future governance cycles

Perhaps one of the clearest signals from the first wave of ORAs is the role they are playing in shaping future governance activity. Completed ORAs are being used to influence how review cycles are structured over the next three years, and how ORA requirements are integrated into business‑as‑usual governance.

This has included greater alignment with existing governance calendars, more deliberate sequencing of reviews, and clearer articulation of the evidence that will support future assessments. In this way, the first ORA acts as a bridge between implementation of the General Code and a more embedded, sustainable governance model.

Looking ahead

The first ORA was always likely to feel distinctive, arriving at the end of a period of regulatory change and concentrated governance development. Subsequent ORAs are expected to be more iterative in nature, as they increasingly draw on established processes and routine monitoring.

What the first wave demonstrates is that ORAs can provide meaningful insight when approached as reflective assessments that support governance decision‑making, rather than as reporting requirements in their own right. This is most evident where findings are translated into clear, tracked actions – demonstrating how the ORA is influencing ongoing activity rather than simply documenting activity.

The challenge now is to build on that foundation by embedding ORA principles and activity within normal governance practice, so that it supports a continuous cycle of review, prioritisation and ongoing improvement.