Robin Ellison puts forward some ideas for the incoming TPR chair
In the latest in his series of columns for Professional Pensions, Robin Ellison imagines a letter the new chair of The Pensions Regulator might write to his or her staff.
AI is amazing: if we ask it to produce a business plan for an incoming TPR chairman, soon to be announced, it will say the following...
"This business plan provides a strategic roadmap for the incoming chair of The Pensions Regulator (TPR), outlining the organisation's priorities, key objectives, and actionable steps for the period 2025–2028. TPR is entrusted with protecting members' benefits, promoting good administration of work-based pension schemes, and reducing the risk of pension scheme failure. The following plan is designed to ensure TPR remains effective, adaptive, and trusted in an evolving pensions landscape."
... and produce a lot more strategic vision, key objectives, and operational priorities, governance and accountability, risks and mitigation, implementation timeline etc. It goes on for pages.
All in TPR and Department for Work and Pensions (DWP) language.
But a real person might write something more down to earth. The incoming chairman (yet to be announced) has written a draft of the letter he/she/they is about to issue.
Hi, pension trustees, plan sponsors and pension scheme members…
I thought it might be helpful to set out how, working with the board and the executive team, I might endeavour to help you operate with less bureaucracy and more efficiency, and together meet the government's aim of helping the UK become more productive (including in particular lowering the burden of regulation). It is both a welcome and farewell letter. So here goes…
1. Before I start, just to mention I don't care what you call me, within the bounds of mutual respect. So: chair, chairman, chairperson, whatever you like. And to thank the DWP, the minister, the prime minister and the select committee for reposing their faith in me to help reform TPR. And to acknowledge that there have been some modest reforms already, with the improvement of the calibre of staff, and some rather primitive / high level training in regulatory principles. But a long way to go…
2. To meet the government's aspirations, we need to downsize. That is not in the current business plan, but must be. We are currently 1,000 people and that's absurd. To manage around 5,000 schemes we maybe need no more than 100 people with autonomy and accountability. And we need to move our offices from Brighton to London (or maybe Manchester, Birmingham or Leeds) if only to cut transport costs and travelling times for our staff and our schemes. We will ensure that no more than two of us will ever need to meet schemes, and we will sell off the minibuses in which we normally travel.
3. TPR have argued that the future of TPR is a matter for DWP and not TPR; that's true in theory but we all know that's not true in practice. So, I will prepare with the team a plan for our eventual dissolution. There is no evidence at the moment that we add value, and we certainly add expense. Pension schemes have trustees and advisers, of varying quality, but we have not added much if anything to their advice, nor to member outcomes over the years. So almost certainly time to wind-up. Especially since we are now living in a time of surpluses.
4. In the meantime, given there might be a high political price to pay for dissolution in current circumstances, we need to be better all round in our daily activities. It is not acceptable that we are less transparent than MI5 (https://www.mi5.gov.uk/, amazing, eh?), so we will make available contact details of all our senior staff on the web (mentioned below), and we will publish (duly redacted only where strictly necessary) our minutes and working papers within a month. And we apologise for not having done it before.
5. We will not be triumphal when we win a case, and we will apologise when we are chastised by the courts as we have been recently. And we will reflect on why there are so many appeals against our fines and whether we can encourage better behaviour by means other than sanctions.
6. We will empower front-line staff to give helpful and practical advice, even where it involves breaking statutory requirements; the Director of Public Prosecutions (DPP) does it and we can too. It is ridiculous for example that we still insist on actuarial valuations for schemes that have almost completed their buyouts. We, like the Financial Conduct Authority (FCA), are operating a nineteenth century regulatory mindset in the 21st century (explained by Huw van Steenis, UK regulation needs a shift in philosophy, Financial Times, 9 October 2025) and we need to change, quickly.
7. I have a good board with members who enjoy some mildly relevant public and private sector experience – but they are profoundly lacking in pensions and regulatory experience. We always advise trustee boards to have diverse and appropriate experience, but are reluctant to follow our own advice. So, like Wetherspoons and Tesco and ABF, all board members and senior executives, and that includes me, will spend at least four days a year sitting in trustee board meetings so as to learn and experience what of our rules and regulations are performative, and which add value. We will learn the true costs of regulation, the true administrative overheads, the unintended consequences of the pages of rules we constantly produce, the absurdity of our constant exhortations encouraging grandmotherly trustees to suck eggs, and take that knowledge and experience back to our board meetings.
8. In particular, there is governance (good) and over-governance (bad). For example we could drop the performative risk registers. None of us predicted any of the real risks in the last few years, such as a Russian war, or a plague, or rapid changes in interest rates. And nowadays there are only three real risks: cyber, cyber and cyber. Let's be more robust in cutting back the paperwork.
9. In the meantime we will prioritise what we will supervise; we will
- scrap the 277 questions (I know, I couldn't believe it when I came in) required to be answered when composing the forthcoming statement of strategy. One paragraph is fine;
- issue simple, generic, half-page guidance on DEI and ESG concerns, and forswear their enforcement; and
- introduce ‘tell me once' for PPF, TPR and HMRC returns.
We have learnt, I think, from the nonsenses that were chair's statements. We will commit to repealing regulatory creep – there is no evidence that further regulating trustees and administrators will improve member outcomes. The potential scandals around the appointment of sole trustees can be coped with by simply insisting they have professional indemnity insurance; and insurers will price the risk.
10. Finally, I will be visible and contactable. If currently you want to speak to someone at TPR, but don't have their contact details, at the moment I am ashamed to say there is no switchboard, and if you wait through the interminable range of options when you ring the number displayed on the website, and eventually click on ‘5', the respondent will say that they are not authorised to give out direct phone numbers, or email addresses, and the generic email address that is given indicates they will get back to you in 10 working days. That demonstrates a profound lack of accountability and transparency. All of us will go to as many conferences as we can (and listen more than we speak) and meet as many of you as is possible, and my email and phone number are now on the website, as are the emails and numbers of all senior executives. Please call me by my first name when we meet, and feel free to drop me a line if you have any concerns,
Yours ever,
Janet or John
DEI for sailors: lessons for TPR
Another regulator, the Royal Yachting Association, also produced some DEI guidance like TPR a little while back (RYA Guidance: Modern Day Manners A guide to Inclusive Language), and struggled with converting salty sea language into woke terms. Some of it is not unreasonable, but it couldn't really cope with which what tyro sailors learn on the first day of risk management, namely how and when to say ‘man overboard'. None of the suggested DEI-compliant alternatives have the sense of urgency that the situation demands. Probably best to let sleeping dogs lie, if we can say that. (https://www.rya.org.uk/news/rya-inclusive-language-guidance/) And there may be a lesson in it for us; maybe we can revert to using members rather than savers in our own world – it is clearer and less ambiguous.
Not a very good criminal
The FCA celebrated the conviction of Daniel Pugh who promised returns of 350% a year if we let him manage our money, and who succeeded in raising £1.3m from his bedroom through Facebook. But he only stole £96,000 (spending on designer clothes, restaurants and cash). He got seven and a half years in jail when prosecuted by the FCA (which might have prosecuted itself for allowing the theft, and complained against itself for breaching the nostrum that they shouldn't be both investigator and prosecutor). Mr Pugh is not allowed to be a company director for 8 years after he leaves jail. That will teach him. (FCA secures convictions against individual for £1.3m Ponzi scheme, FCA Press Release , 07/08/2025 https://www.fca.org.uk/news/press-releases/fca-secures-convictions-individual-ponzi-scheme).
Pensions and the movies: the actuary as superman
Actuaries get a bad press from time to time, and it doesn't help that they are supervised by a regulator, the Financial Reporting Coucil, that also (deservedly) gets a bad press. But have a look at this clip from the miniseries, Person of Interest, https://www.youtube.com/shorts/HWKN9ZyJlqI where a good-looking male ‘actuary' is dining with a good-looking female ‘journalist' who doesn't like champagne (eh?) who doesn't realise he really is a comic book superhero. As are all actuaries.
Pensions misspelled: need for a new regulator
Imogen Poots is an increasingly celebrated actor, with a recent write-up in the November 2025 issue of Tatler, which reports:
"Always a keen artist, she takes the subway uptown or to Chinatown most evenings to attend life-drawing classes. ‘You're around people who've been going there for years and years, with amazing stories,' she says. The results are posted on her art Instagram, @~misery_pocket, accompanied by witty captions. Recently, her teacher told her off when she drew one young male model's penis ‘too big'. ‘You have to commit with genitals. You have to really dig in with the pencil, but then I had to rub it out, although the guy came round looking at our work and you could still see my [original] outline. I don't think it ruined his life.''
That's good advice for aspiring artists, but she would have benefitted from perimeter guidance from The Artists' Regulator which sets out that students should treat life models and their appendages with respect.
Robin Ellison is, among many other things, the chairman of the College of Lawmakers, a retired pensions lawyer, a visiting professor in pensions law and economics at Bayes Business School, City, University of London and chair of several pension funds
If you want to hear more from Robin, he is featured on the latest episode of the Pension Barrister podcast, Talking Pensions, being interviewed by Paul Newman KC.
