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Supervision enables us to have contact with the trustees, managers and sponsoring employers of pension schemes.

It helps us to:

  • monitor schemes closely
  • clearly outline what we expect
  • act quickly where we have concerns

The actions we take will depend on the risks that we identify.


We are temporarily suspending our regulatory initiatives and have scaled down the Relationship Supervision evaluation cycle while we focus our resources on supporting schemes that need our ongoing attention. This includes those affected by the COVID-19 pandemic.

If you have been selected to take part in a regulatory initiative or your scheme is in Relationship Supervision, we will be in touch with you regarding our expectations and next steps.

You can read more on the evolved response of supervision to the COVID-19 pandemic in the blog from Charles Counsell, TPR Chief Executive.

Regulatory initiatives and applications

Regulatory initiatives involve us contacting a large number of schemes about a particular risk and engaging with those that have not adequately addressed the risks we identified.

We seek assurances from the schemes about how they will assess the risk, and if their response does not adequately address it we will engage directly with the scheme or other stakeholders to do so.

We also deal with applications, including those for clearance and regulated apportionment arrangements. We review all applications we receive and respond promptly, recognising commercial timescales of the underlying transactions.

Relationship Supervision

Relationship Supervision allows us to extend our reach across the market and develop relationships with strategically important schemes.

It enables us to monitor schemes more closely, outline our expectations, and prevent problems from developing in the first place. Supervision involves building strong relationships with schemes regardless of whether they trigger our traditional risk indicators.

We supervise defined benefit (DB) schemes, defined contribution schemes (including master trusts) and public service pensions using a range of criteria to select them. These criteria include:

  • size
  • risk
  • previous interactions with us

We assess the risks and strengths of the scheme by reviewing its management and governance, systems and processes, IT and infrastructure, control functions, administration and member communications and, for DB schemes, funding. We may not need to look at all these areas for every scheme.

We then set out our findings in a supervisory report and ask the scheme to create an action plan to address the recommendations we make. We have regular meetings to review their progress and, where necessary, refer issues to our enforcement teams to take action.We expect schemes to be in Relationship Supervision for at least 18 months, and will periodically review how long they should remain in supervision. We meet most schemes at least twice a year - having a close working relationship enables those running schemes to be open and transparent with us and have a dedicated point of contact at TPR.

However, due to the ongoing COVID-19 pandemic, our Relationship Supervision cycle has been scaled down. More details on our supervisory activities.

Case study: First UK Bus

First UK Bus is one of the largest bus operators in the UK, with a fifth of the market outside London. Its defined benefit (DB) pension scheme had 4032 active, 12773 deferred and 9124 pensioner members, assets of £1.24 billion and liabilities of £1.51 billion on 5 April 2019.

We began our supervisory relationship in November 2019 and looked at the scheme’s governance and administration processes, including its funding and risk management approach. Since the beginning of our engagement we have had a number of face-to-face meetings with the trustees, many teleconference calls, and they also receive our regular stakeholder communications updates. 

Our involvement coincided with the scheme’s triennial valuation, where a new recovery plan was agreed that will lead to the scheme being fully funded within the next 10 years. Although we had previously had some communication with the trustees, the supervisory relationship marked a new way of interacting, which has been overwhelmingly positive for engagement and outcomes. This can be seen not only in the improved funding of the scheme – the employer has agreed to increase deficit repair contributions from £18 million to £33 million per year – but also in the way scheme members relate to their pension. The trustees now send members an engaging and accessible newsletter, giving details of the scheme’s financial status and including clear examples of how small increases in contributions could make a huge difference to their retirement.

The two co-chairs of the trustee demonstrated a real desire to learn from the supervisory relationship, describing it as positive and helpful. They have embraced a number of trustee specific training exercises, one of which relates to Environmental and Social Governance (a key area of focus for TPR).

Event Supervision and Rapid Response

Our Event Supervision and Rapid Response teams respond quickly to reports of events which pose increased risks to schemes. This will generally involve events that affect the employer covenant supporting DB schemes, particularly corporate transactions or corporate distress.

We assess the impact of an event on a particular scheme and on our statutory objectives. Where we get involved, it is initially through the trustees as they are the first line of defence for savers and, if appropriate, we will engage directly with trustees, employers and other stakeholders to protect the interests of members.

Our Intelligence team identifies schemes facing heightened risks and we then contact the trustees very quickly to look at key areas such as:

  • how they are assessing the likely impact of an event on the scheme
  • whether they are getting the right information and advice
  • what protections they already have in place and if they can be improved

We establish whether the trustees have the right skills, experience and advice to address the particular issue they are facing and assess the level of risk to members. Some trustees will have very little experience of certain events so they benefit from our experience, but we are not a substitute for effective trusteeship.

Where required, our Event Supervision team will engage more directly in the situation faced by the scheme. Our team members have significant experience of corporate transactions and restructuring and will engage with relevant stakeholders to ensure the scheme’s position is appropriately protected.