AMNT believes that there are a number of areas that need to be addressed, which it has highlighted in its response. These include:

Inequality and the Gender Pensions Gap: The strategy inadequately addresses the underlying causes of unequal pension outcomes. Women are disproportionately affected by lower earnings, part-time working, and caring-related career breaks, which compound over decades into significantly lower retirement incomes. tPR should explicitly address the gender pensions gap and structural causes of unequal outcomes in the strategy.

The Vision Needs Greater Ambition: "Sustainable income" should explicitly mean dignity, adequacy and financial wellbeing in retirement — not merely a basic adequate income. The consultation acknowledges that 14.6 million people are not on track for adequate retirement income. This must be addressed.

The contribution and importance of Member-Nominated Trustees is under-appreciated: The strategy focuses on professional trusteeship while barely acknowledging MNTs. AMNT believes that member representation is a defining strength of the UK trust-based pension model and must not be diluted as consolidation accelerates.

Risks from Consolidation and Master Trust Concentration: Larger or consolidated schemes do not automatically produce better governance or member outcomes. And the extreme concentration of power in a smaller number of professional trustees going forward is a threat to member representation. The voice of the member must continue to be heard. tPR should increase assurance activity on conflicts of interest in master trust boards and strengthen oversight of professional trustee firms and administrators, especially where concentration is growing. tPR should issue clearer trustee capability expectations and stronger training pathways for all trustee types, not just professional trustees.

Decumulation and CDC Are Insufficiently Prominent: The next five years will see major developments in decumulation pathways and Collective Defined Contribution (CDC) schemes. AMNT highlights a significant member communications and literacy gap — many members believe they "have a pension" when they actually hold savings pots with no clear income pathway.

Fiduciary Duty Must Remain Primary: AMNT urges tPR to exercise extreme caution about framing pension schemes as vehicles for UK economic growth. Any such language must not create the impression that trustees' fiduciary duty to members is subordinate to broader political or economic objectives.

AI Governance: Given the breakneck pace of AI development and adoption, tPR should issue guidance on AI governance, particularly around automation in member-facing decisions and the serious risks of sharing member personal data with open AI toolsets.

Additionally, “The document conflates fiduciary duty with UK growth objectives in places, uses the unexplained phrase "independent" trustees in its concluding paragraphs, omits CDC from its discussion of future DB/DC challenges, and fails to acknowledge the role of investment consultants and managers in supporting trustee decision-making”, said Lewis Brown.

-Ends-

Notes to Editors

The Association of Member Nominated Trustees was established in September 2010 to bring together member-nominated trustees, directors and representatives of public and private sector pension schemes to give trustees a collective voice, to provide mutual support and information exchange and to campaign on matters of concern.  

In addition our membership is focused on speaking on behalf of pension scheme members, because being a scheme member is a requirement for becoming an MNT and has a particular part to play in scheme governance. Our members are from pension funds with collective assets of approximately £1-trillion.

‍For further information please contact Andrew Sharkey on 07711 825 439