Embracing change

There have been tumultuous shifts in the political, economic and pensions landscape since TPR’s inception 12 years ago.

We’ve seen the introduction of automatic enrolment, continued economic challenges to DB schemes and the introduction of new pension freedoms. TPR has been given responsibility for regulating the governance and administration of public service schemes and we’ve successfully made the case for new powers to protect savers in master trusts.

No organisation exists in a bubble and TPR is changing. We’re striving to be clearer, quicker and tougher in what we do. Major cases have highlighted the work we are already doing to evolve and adapt as an organisation.

Settlements achieved in the BHS and Coats cases – amounting to almost £700 million recovered for pension savers in total – have increased our profile and driven greater scrutiny of our actions. Elsewhere, our work to drive up basic standards of governance by issuing fines where schemes fail to complete basic duties, prosecuting those who fail to provide the information we need for our investigations and our work to ensure that employers meet their pension automatic enrolment duties illustrate how we are intervening decisively to influence behaviours.

Given the depth and breadth of change, it’s absolutely right we take a good look at ourselves and the way we work, taking into account the changes already happening and further challenges on the horizon.

That’s why we put in place a structured programme called TPR Future last autumn. We want to ensure we change in the right way and have the right culture, capabilities and set of regulatory approaches and interventions available to us to address the challenges we face for now and in years to come.

We’ve reached the conclusion of the first phase of the programme. We spoke to over 150 of our stakeholders – trustees, employers and other regulators – conducted research with a further 70 and sought the views of our own staff.

Having analysed this feedback, we’ve identified five key areas where we can change and improve:

  • identity – being more clear about who we are, what we do, our focus and priorities
  • expectations – being clearer what our expectations are and the consequences when they are not met
  • regulatory oversight – improve our horizon-scanning, data and use of technology to identify risks and better target our interventions
  • regulatory interventions – we will use our powers more frequently and quickly, making use of our full range of powers
  • efficiency and effectiveness – have the right processes in place to adapt to the fluctuating challenges we face, measure and manage our performance, and improve consistency

We are learning the lessons of our high-profile cases, but they are not the main or only agent of change. Nor is this about lobbying for new powers.

TPR Future is about what we need to do as an organisation to be ready to tackle the challenges we face. We need to be poised to address new and specific risks – the inability for some schemes to ever reach the standards we expect, economic conditions placing further pressure on schemes, changes in the employment market and the rise of a gig economy, the impact of Brexit, and other threats to pensions such as cyber attacks.

Our ‘educate, enable and enforce’ approach has served us well since 2005, but we now need to develop multiple regulatory approaches across the areas we regulate. This means different techniques, including more systematic proactive work with higher risk schemes, thematic work and driving up standards through use of the full range of our enforcement powers.

We can learn lessons from automatic enrolment which has highlighted how we can drive behaviours and bring about positive outcomes by establishing clear journeys, being clear about what employers must do and taking action if this does not happen.

Today, we met the stakeholders whose engagement is helping us to develop and shape TPR Future. We updated them on our progress so far and received thought-provoking input for the next phase of our work.

Our task now is to design a set of regulatory approaches that are fit for purpose for the next five to ten years. We expect this to take in the order of six to eight months and we may well test and pilot some approaches before moving to full implementation.

We’ve published an update on TPR Future where you can read about our progress so far.

Lesley Titcomb

By Lesley Titcomb
Chief Executive Officer