In December 2025, The Pensions Regulator (TPR) published updated guidance on pension scheme administration. While administration has traditionally been viewed as an operational function, the regulator is now clear: it is a strategic driver of member outcomes and a core governance responsibility.
For trustees, this represents a material shift in expectations. For schemes and their advisers it creates both challenges and opportunities.
A step change in regulatory expectations
TPR’s updated guidance is designed to help trustees meet the standards set out in the Administration module of the General Code of Practice, which came into force in March 2024. The message is clear:
- Administration is no longer a “back-office” activity
- It is fundamental to delivering good outcomes for savers, see: TPR Press Release
- Trustees remain fully accountable, even where services are outsourced, see TPR detailed admin guidance
The guidance consolidates expectations across several areas, including governance, data, systems, and service delivery, and sets out practical steps for trustees to improve oversight and control.
What’s new (and why it matters)
While much of the guidance builds on existing principles, several themes represent a significant uplift in expectations.
1. A formal administration strategy is now expected
TPR explicitly highlights the importance of schemes having a written administration policy or strategy, supported by clear documentation and defined responsibilities.
For many schemes, this will expose a gap:
- Documentation exists (contracts, SLAs, processes)
- But there is no single coherent framework setting out how administration is governed
Insight: Developing an administration strategy is now a key step in demonstrating compliance with the General Code and embedding an effective system of governance (‘ESOG’).
2. Stronger oversight of administrators
The guidance places significant emphasis on active and evidence-based oversight. Trustees are expected to:
- Establish robust monitoring frameworks
- Use broader performance metrics, beyond simple timeliness
- Focus on quality, accuracy, and member outcomes
Insight: Many trustee boards rely heavily on SLA reporting that does not fully reflect service quality. This creates blind spots.
3. Data and administration are now strategic assets
TPR reinforces the importance of:
- Accurate and complete data
- Strong record-keeping
- Proactive data management
This is particularly relevant given pensions dashboards, endgame planning (buy-out, consolidation, run-on) and increasing member expectations.
Insight: Data quality is no longer just an administrative concern, it is a critical enabler of strategic outcomes.
4. Technology, systems and resilience in focus
The updated guidance introduces strengthened expectations around:
- Administration IT systems and controls
- Change management and system assurance
- Cyber security and resilience
- Business continuity planning
Insight: Trustees are expected to understand, not just rely on, the systems used to administer their schemes. This is a notable shift for many trustee boards.
5. Administrators as partners, not providers
TPR emphasises the need for effective partnerships between trustees and administrators, supported by:
- Clear contractual arrangements
- Defined responsibilities
- Structured service management frameworks
Insight: This signals a move towards more strategic, collaborative relationships, rather than purely transactional outsourcing.
What should trustees be doing now?
TPR expects governing bodies to use the guidance as a practical framework to review and strengthen their administration arrangements. In practice, this means asking:
- Do we have a documented administration strategy?
- Are our oversight and reporting frameworks fit for purpose?
- How confident are we in our data quality and controls?
- Do we understand the systems and risks underpinning administration?
- Are our administrator relationships and contracts aligned to current requirements?
For many schemes, the answer will highlight areas requiring further work.
Administration is key
While the guidance is regulatory in nature, its implications go beyond compliance. In our experience, administration sits at the heart of several strategic priorities:
- Endgame readiness (buy-out, consolidation, run-on)
- Cost efficiency and risk reduction
- Member experience and engagement
Poor administration can directly impact outcomes in each of these areas, through data issues, processing errors, delays and inefficiencies. Conversely, a well-governed administration function can unlock significant value.
How we can help
The updated guidance creates a clear need for structured review and improvement. We are supporting schemes with independent input in the following areas:
- Administration effectiveness reviews: Assessing current arrangements against TPR expectations
- Administration strategy development: Building a clear, compliant governance framework
- Oversight and KPI framework design: Moving beyond SLA-based reporting and defining quality measures
- Systems assessments: Supporting data improvement and technology decisions
- Requirements definition and refresh: Helping trustees clearly define, document and update their administration requirements to align with evolving regulatory expectations, scheme needs and endgame strategy
- Administrator benchmarking and tender exercises: Ensuring the right delivery model is in place
Final thoughts
TPR’s 2025 guidance marks a clear evolution in how administration is viewed. From operational necessity to strategic priority. Schemes that respond proactively will not only meet regulatory expectations, but also be better positioned to deliver stronger outcomes for members and navigate an increasingly complex pensions landscape.
If you’d like to discuss what this means for your scheme, please get in touch with Susan or your usual consultant.