Sackers has issued guidance and tips for trustees looking to prepare their first ‘own risk assessments’ (ORAs).
Depending on the scheme’s reporting dates, some trustees will be looking to complete these assessments in March this year. Sackers points out that The Pensions Regulator has not provided a set template for these assessments, which may leave trustees unsure how best to proceed with these new regulatory requirements.
Sackers partner Helen Baker says: “For many schemes, 2026 will be the year of their first ORA. From our experience working with trustees across a wide range of schemes, some key themes have emerged to help guide the first ORA.
“First, it’s important to tailor the ORA to your scheme. There is no single ‘right’ approach, and different schemes will have different governance needs.
“Second, focus on risk: consider how risks are identified, assessed and managed, and pay attention to emerging risks such as cyber security and AI, and on areas of focus from the Pensions Regulator, such as administration.
“Finally, make it a meaningful assessment. The ORA is not a tick‑box exercise; trustees should evaluate whether policies and procedures are effective, meeting their objectives, and include clear processes for addressing issues where they arise. Using real examples and highlighting areas for improvement will add real value to the process.”
Sackers adds that as this is a new process there is a learning curve for all involved. “Trustees should focus on what is actually required and on the risks that matter to their scheme, while having a clear plan for work that still needs to be done.
“An ORA isn’t an exam, the goal isn’t to get the best mark. Instead, think of it as a health check for your scheme – a regular opportunity to look under the bonnet, spot any issues and ensure everything is running smoothly.
“As it’s now part of the governance cycle it provides a three-yearly opportunity to take stock and set the forward agenda for scheme governance.”
She adds: “Even the best-run schemes are likely to find areas where recent developments, such as those relating to administration or cyber, mean there is more to do. Clear prioritisation, focus and planning will help trustees navigate the first ORA and set strong foundations for those to come.”
