I must admit I wrote to Nausicaa Delfas to thank her for her speech. It is the first time I’ve heard the Pensions Regulator speak of CDC as a (let alone the) way forward. But I feel bound to give the view of my old friend Derek Scott.
This blog is by Derek Scott – ” A Retired Pensions Trustee”.
Derek Scott
This anniversary speech reads to me less like a balanced assessment of a profession and more like just a ceremonial endorsement that quietly sidesteps the profession’s mixed record to date.
A missed opportunity.
The praise is not just generous—it’s structurally insulated from evidence.
The speech opens by contrasting a “simple” past with a “complex” present, implying that rising longevity and system complexity justify the continued centrality of actuarial judgements.
That framing is convenient.
It avoids asking whether actuarial models and advice contributed to the very challenges now described—most notably:
In DB, underestimation of longevity improvements, procyclical funding approaches, and liability-driven investment strategies that amplified systemic fragility (as seen in the 2022 gilts crisis).
In DC, a design heavily shaped by actuarial and policy consensus that prioritised participation over adequacy, resulting in contribution rates and lifecycle investment strategies that are widely acknowledged to be insufficient.
By attributing today’s problems to external change rather than professional limitations, the speech pre-emptively absolves the profession.
Phrases like “trusted guides,” “strategic advisers,” and “your advice is critical” are repeated as axioms, not as defended claims.
There is no attempt to test these assertions against outcomes.
If actuaries are indeed central to decision-making, then the persistent inadequacy of retirement incomes and the self-destruction of many DB schemes should prompt scrutiny of their advice, not just celebration of their role.
The only nod to system failure—“outcomes that fall short”—is carefully depersonalised.
Responsibility is assigned to “the system” rather than to the actors (which must include actuaries) who designed, regulated, and advised within it.
There’s an implicit circularity in a regulator praising the very experts it relies on.
The line about moving to “expert to expert engagement with you” is telling: it suggests a closed epistemic loop where actuaries both shape and validate the framework within which pensions operate.
That surely risks reinforcing groupthink rather than challenging it.
The call for actuaries to “help us raise standards” further blurs the line between a regulator and the regulated.
It positions the profession not as an object of oversight, but as TPR’s partner in defining what “good” looks like—despite that partnership’s very mixed historical performance.
The role of professional advisers such as actuaries is to provide specialised expertise, sound advice, and proactive challenge to help clients make informed decisions and manage risks and opportunities. Simply parroting regulatory guidance on behalf of a regulator falls far short of my own expectations of professional
advice.
The lack of clarity in recent TAS 300 reporting to trustees and employers is just one example of where we need to understand far better what actuaries are saying behind closed doors.
The sections of the speech on DB, DC, and CDC reframe longstanding issues as opportunities for actuarial expansion:
DB’s very troubled history becomes a “more hopeful” phase, with little acknowledgement of how previous funding and investment advice contributed to unnecessary scheme closures and serious misallocations of employers’ capital resources.
DC’s weaknesses—especially at decumulation—are presented as a new frontier for actuarial input, rather than a gap that actuarial thinking has helped leave unaddressed.
CDC is cast as an exciting new design space, again positioning actuaries as architects of the future without reflecting further on the lessons to be learned from past design failures.
In each case, the profession’s remit grows, but its accountability does not.
The speech consistently uses passive or collective language—“the system has not yet caught up,” “change is possible,” “we can finish the job.”
This diffuses responsibility across an abstract “we,” masking the influence of specific actors and ideas.
It also creates a narrative of inevitable progress, in which my critique may feel almost churlish.
A genuinely balanced address might have included:
Acknowledgement of past forecasting errors (e.g. longevity, investment opportunities) and their consequences.
Reflection on the role of actuarial advice in shaping low DC contribution defaults and outcomes.
Recognition of systemic risks introduced by widely recommended, and hence adopted, strategies like LDI, particularly leveraged LDI.
A clearer distinction between where actuarial expertise adds value and where it has fallen short.
Without these counterbalances, the speech functions just as yet more professional affirmation rather than as serious reflection.
It’s a classic “anniversary” speech: cohesive, optimistic, and politically smooth.
But analytically, it’s thin.
It elevates a profession’s importance while treating its very mixed track record as mere background noise.
For a pensions sector grappling with adequacy, and trust, that lack of self-critique is not just a rhetorical gap—it’s very much part of an ongoing problem.
