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ACA calls for three ‘key additions’ to TPR strategy paper

by Christopher Marchant
June 5, 2026
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The Association of Consulting Actuaries has recommended a few ‘key additions’ in response to The Pensions Regulator’s consultation on its future strategy.

The professional body acknowledged that TPR is aware of the specific challenges relating to the rising prevalence of professional trustees, including appropriate conflict management. However, it also asserted that these potential conflicts will become even more important to manage when the surplus flexibilities are in force, and given the significance of these issues, its view was that this would warrant explicit comment in the strategy.

The ACA also claimed that collective defined contribution plans will be key to achieving TPR’s vision of a sustainable income in retirement. In addition, TPR will need to devote adequate resources to ensure that new CDC arrangements can be considered and authorised in a timely manner.

Chintan Gandhi, chair of the ACA, says: “It will also be important for the development of Retirement CDC to be integrated with the development of guided retirement. Suitably aligned timings will be key – and these could have a significant impact on TPR achieving its vision.

“In addition, we think that the strategy should more clearly state that TPR will be actively supporting CDC innovation as one of its key priorities. We anticipate that this will be the case in practice, but it would be helpful to make this clear in the strategy.”

The ACA has made the remarks in response to TPR’s plans to update its corporate strategy over the next five years in the context of a rapidly changing pensions market. The regulator is currently seeking feedback from stakeholders on a draft version of the strategy before publishing a final version later this year.

The consultation is due to close on 8 June.

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