TPR’s expectations for AI governance

On 20 May 2026, The Pensions Regulator (TPR) published a press release and its own AI plan setting out TPR’s initial expectations for how use of artificial intelligence (AI) should be governed in workplace pension schemes.

TPR highlights AI’s potential to improve administration, support more informed decision‑making and enhance member engagement, while emphasising the need for schemes to use it in a way that supports member outcomes and maintains trust.

TPR intends to engage with the industry over the summer on AI use in workplace pension schemes and their supply chains, ahead of publishing more detailed guidance later in 2026.

What TPR expects from trustees now

TPR indicates that trustees and administrators should take steps now, rather than wait for detailed guidance later this year. Trustees remain accountable for outcomes and should oversee how AI is used across the scheme and its service providers. Consistent with expectations under TPR’s General Code on governance, risk management and internal controls, trustees are expected to:

• Establish governance arrangements for AI use, obtaining assurance that administrators, advisers and other service providers have similarly robust arrangements in place
• Assess and manage AI-related risks, including bias, cyber risk and AI‑enabled scams, with controls reviewed regularly
• Understand and respond to AI‑driven fraud risks, including emerging threats and the risk of members relying on AI tools for financial decisions
• Strengthen data governance and quality, including maintaining a clear data strategy, allocating appropriate resources for improvement and meeting data protection requirements
• Take professional advice where appropriate and proportionate, particularly when implementing or relying on AI‑enabled solutions

TPR also recommends that trustees remain informed on emerging standards, are transparent with members and stakeholders where appropriate, and share experience and good practice across the industry.

What the AI plan adds

The AI plan provides greater clarity on TPR’s strategic direction and how expectations are likely to develop, including:

• Trustee and governance standards: TPR will work with the industry and government to strengthen trustee and governance standards, including the Financial Conduct Authority and other regulators to support a consistent regulatory approach
• Data as the foundation for AI: continued focus on data quality, common standards, and greater use and sharing of data to support safe and effective AI adoption
• Innovation: TPR will facilitate innovation through its innovation service and regulatory collaboration, and ensure its material is accessible and usable for AI systems, while ensuring appropriate safeguards are in place to protect members (including under the forthcoming guided retirement duty under the Pension Schemes Act 2026)
• TPR supervision: TPR will use AI to enhance risk identification and monitoring, and to support a more data‑driven supervisory approach. It will publish further detail on its use of AI this year
• Reporting: TPR will report annually on AI progress across the pensions industry and develop metrics and evidence to monitor AI adoption

TPR invites wider industry participation in the work of the Pensions Data and Digital Industry Working Group, including contributing expertise, sharing good practice, or joining a subgroup (ddatgroup@tpr.gov.uk).