We are consulting on a new enforcement strategy that reflects our evolution into a more proactive, prudential regulator. In this blog, Gaucho Rasmussen sets out our targeted, outcomes-driven approach to using our powers – focused on behaviours and risks that matter most to savers. For trustees and industry bodies, it offers greater clarity and confidence. We welcome views to help shape a strategy that supports high standards and strengthens trust in the workplace pensions system.
Our new proposed enforcement strategy reflects a continuing and significant shift in how we regulate. It introduces a more focused, agile, and outcomes-driven model – one that is aligned with our statutory objectives, our corporate priorities, and our transition toward a more prudential and supervisory-led style of regulation.
The strategy acknowledges that we will take a pragmatic, strategic, evidence-based approach, choosing the most effective tool for each case based on the risks and harms involved and the outcomes we are seeking.
It recognises that in most cases, it is better to:
- have expert-to-expert conversations with the people who run pensions to understand why things are going wrong at an early stage
- prevent things from going wrong before they escalate
- be clear about our expectations from the start
- work with trustees and employers to put things back on track and repair any damage as quickly as possible
However, where co-operation fails, we will take stronger action to protect savers.
A new framework
At the heart of this strategy is a clear enforcement framework which aims to achieve one or more of four key outcomes: prevention, reparation, accountability, and saver confidence.
These outcomes will guide our decisions and ensure that our actions are proportionate, purposeful, and aligned with our mission to ensure savers receive outcomes that matter.
So, what does this mean in practice? It means we are committed to delivering enforcement that is both effective and efficient. We will:
- protect savers from harm
- raise compliance and standards across the pensions landscape
- support a system that works in the best interests of savers
We want to be in a stronger position to respond to emerging risks, act decisively when standards fall short, hold individuals and organisations to account, and deliver positive outcomes for savers.
This is not just a refinement in how we do things. It is an evolution.
While building on our existing strengths, our new strategy introduces a more targeted and responsive model that reflects the changing risks in the pensions landscape and our broader regulatory transformation.
Not only will we uphold standards and protect savers, but we will foster a well-functioning, transparent pensions sector that contributes to long-term economic growth.
Strategic objectives to guide our enforcement approach
Our enforcement strategy is underpinned by five strategic objectives, each designed to support our statutory objectives and the broader aims of our corporate plan: protecting savers’ money, enhancing the pensions system, and supporting innovation in savers’ interests.
- Targeted enforcement that tackles key risks and harms
We focus our enforcement efforts where the risks to savers are greatest and where our actions can deliver the most meaningful impact. - Driving impact through assertiveness, agility, and collaboration
We work to identify risks early, consider enforcement options from the outset with our Market Oversight team, set clear expectations, and shape responses that are timely and effective. We also collaborate with external partners to share intelligence, drive compliance, and co-ordinate responses across the pensions sector. - Decisive action against non-compliance and economic crime
Where there is an immediate risk to savers or scheme assets, we will move quickly to use our powers. In cases where we suspect serious economic crime, we escalate matters swiftly and co-ordinate a response with our law enforcement partners. We also work to ensure victims receive support throughout the process. - Enhanced transparency and building trust
We want the industry and savers to clearly understand our expectations around good conduct, the risks they face, and how we respond. By publishing enforcement outcomes, we highlight key risks, clarify our expectations, and promote improved compliance and behaviours across the sector. - Data-driven enforcement for a stronger pensions system
By investing in digital tools and analytics, we can detect trends earlier, respond more quickly, reduce regulatory burden, and focus our efforts with greater precision.
Our enforcement activity will focus where the harm to savers is greatest and where we can deliver the most impact.
This shift reflects a more deliberate and targeted approach. That does not necessarily mean doing less. It means focusing our efforts on what matters most: delivering real outcomes for savers and driving meaningful change.
When considering potential actions, we will respond in ways that are proportionate and effective. This may include targeted communications or compliance-led interventions, with appropriate escalation where evidence of non-compliance emerge.
This approach supports a more agile, risk-based regulatory model that protects savers, promotes high standards, and contributes to a stronger, more resilient pensions system.
Next steps
We plan to publish the final strategy and a summary of consultation responses in early 2026. Later in the new year, we will review our full suite of published policies to ensure alignment with the new strategy and may consult on any necessary changes.
As we consult on this strategy, we invite you to look beyond the surface and consider what’s truly at stake: the security of millions of savers and the integrity of the pensions system itself.
This isn’t just a technical shift – it’s a cultural one. By embracing a more agile, preventative, and outcomes-focused approach, we’re laying the groundwork for smarter regulation that protects people before problems escalate. So, whether you’re a trustee, employer, adviser or simply someone who cares about the future of pensions, now is the time to engage, challenge, and shape the way forward. Read the strategy, share your views, and be part of the change.
