More thoughts on the future of the Pensions Regulator.



Yesterday , Professional Pensions advertised my blog “two into one can go” under the more contentious headline “why tPR has had its day“. I’ve given Jack Jones editorial licence and the headline’s fine with me.

It was a bad day in Brighton as a number of voluntary redundancies were announced yesterday and I’m sure no-one at the Pension Regulator could have much enjoyed seeing my opinions rubbing salt into the wound. For what it’s worth, this was pure coincidence.

And I’m sure that many people reading the article in a national trade magazine will think I have overstepped the mark. The Pensions Regulator is important to firms such as mine, it approves funding plans, monitors standards and provides work. Many will think that I am biting the hand that feeds.

But this is the problem, if cannot criticise our Regulator , we will not move on . The world is moving on but

Much of this work is going very well. The management of our legacy DB policies is exemplary; a case in point being the resolution of the problems caused by the collapse of Kodak in the US and the means devised to keep pension liabilities out of the PPF and members with benefits, to a great degree, protected from the problems with the sponsor.

On the great body of our pension legacy, there is a huge advisory industry involving asset managers, liability managers, legal , technical and administrative consultants working with the Pension Regulator on an endgame for the defined benefit pension scheme.

It is easy to see this as the main event. But it is not the main event for the majority of employers and the majority of employees in the UK. It is certainly not the main event for those who are outside of employment for whatever reason.

But for historical reasons, tPR has been given control of the regulation of auto-enrolment and responsibility for the standards that operate within occupational schemes, including the master trusts of NEST, NOW and People’s Pensions which are likely to carry the burden of providing pensions to the majority of the 1.2m employers still to engage with workplace pensions under auto-enrolment.

And , as my article makes clear, I do not feel the Pensions Regulator is capable of creating the engagement , education and empowerment of employers necessary for them to choose the right workplace pensions for their staff.

And I think the FCA is.

So I see it as time to move the Pensions Regulator on from being at the end of the branch line to Brighton , to being at the centre of our British regulatory regime in Canary Wharf.

Like Steve Webb, I do not see it as possible to manage the seismic changes that will be brought about by auto-enrolment and the measures in the Treasury and DWP pension bills, with the current structure.

I’m pleased to see that the Pensions Regulator has also decided to renew its search for a CEO to replace Bill Galvin . Bill has now been gone eight months and Steve Soper has done a gallant job holding the fought but to suppose that a major regulator could be without a long-term CEO for over a year, suggests that leadership is not what it is about.

In truth, I don’t look for thought leadership from tPR. I do from the FCA

There are great people at tPR and I have praised them on this blog both for what they’ve done and what they are doing but I’m a practitioner and I need clarity. Without firm leadership there is no clarity and this is evident in much of the guidance coming out of tPR on workplace pensions.

I finished my last blog on this subject by looking specifically at one issue, the provision of advice to small employers about the choice of pension. It is a subject close to my and ‘s heart!

I’ll finish this on the same subject. The OFT have set the pensions industry a challenge- to change our employers from poor pension purchasers to good pension purchasers. The Government is doing its bit by ensuring that all workplace pensions purchased for auto-enrolment  have Minimum Standards from 2015 and that existing schemes used for AE are upgraded by 2016.

Providers operating contract based plans will set up Independent Governance Committees that will ensure these standards are met and maintained. They will operate under a simple guiding principle “Value for Money” and will be overseen by the FCA. Our  comments on how this could work are here

Providers operating occupational pension plans will be subject to the governance framework illustrated here. Please do not ask me to explain this diagram.


In my opinion, the occupational pension governance framework is not fit for purpose , the governance framework for contract based plans is.

We cannot go on with two Regulators doing the same job in such different ways. The FCA must , in time, subsume the Pension Regulator in all but the management of our  legacy body of DB pensions. That function needs a permanent leader and I suspect that it needs to move to Croydon and sit closer to the PPF.

This article first appeared in


About henry tapper

Founder of the Pension PlayPen,, partner of Stella, father of Olly . I am the Pension Plowman
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