The Pensions Regulator has identified progress on data cleansing ahead of pensions dashboards but also highlighted areas where further work is required before schemes connect next year.
According to TPR, most schemes have improved the quality of personal data, while value data used to calculate member benefits has received less attention. The regulator also found that many improvement plans remain “informal or fragmented” and that the levels of trustee involvement vary across schemes.
TPR reported wide variation in controls, with administrators often leading data assessments and trustees providing limited scrutiny. The regulator also referenced its July research, which found that one in four schemes still hold non-digitised records and fewer than three in five are confident in the accuracy of their common data.
The regulatory initiative focused on assessing data and establishing improvement plans as part of dashboard preparation. TPR says it is increasing its engagement as schemes approach their connection deadlines.
The regulator has also published revised member data guidance that consolidates data-related requirements and sets out clearer expectations, including best practice examples to support improved data management.
The guidance states that trustees remain accountable for data quality even when tasks are delegated to administrators and must carry out regular data assessments, review reports and submit accurate data scores in their scheme return. TPR also says trustees should have a defined data management strategy, ensure sufficient resources for improvements and challenge service providers where necessary.
TPR is currently reviewing the data preparations of the UK’s largest schemes and plans to expand its engagement in 2026. Schemes that cannot demonstrate compliance may face formal intervention, including improvement notices.
TPR executive director of market oversight Julian Lyne says: “Good data is the foundation of good governance and a trustee’s most important strategic asset. Trustees are accountable for ensuring member data is correct – no-one else. Maintaining its quality is an ongoing responsibility, because neglect can be costly and have real-world consequences for savers.
“With the pensions dashboard deadline less than a year away, the need for reliable data has never been more urgent. The gaps identified in our report risk undermining dashboard readiness and highlight the importance of trustees adopting robust, consistent practices across all aspects of data management. Good data must be complete, accurate, timely, consistent, unique, valid and properly managed.”
