Broadstone has submitted its response to the Department for Work & Pensions’ consultation Trustbased pension schemes: Trustees and governance, building a stronger future. Our submission sets out a clear vision for the future of trusteeship and governance as the UK’s pension system undergoes profound structural change.
A system transforming at pace
Trustbased pension schemes are entering a new era.
Defined Contribution (DC) schemes are consolidating into a smaller number of large, institutionscale “megafunds”, while Defined Benefit (DB) schemes continue their march toward endgame — whether that is buyout, risk transfer, or longterm runon.
These shifts demand governance frameworks that are more forwardlooking, more datadriven and more resilient than ever before.
Our key themes
1. Governance built for scale and complexity
As DC schemes become larger and more sophisticated, governance needs to evolve accordingly. We argue for clearer riskappetite frameworks, strengthened committee structures, robust challenge around illiquid asset allocations and a stepchange in operational resilience and cyber governance.
2. Stronger data integrity and administration oversight
Administration is now a critical systemic function. With millions of members concentrated on fewer platforms, failures in data quality, system migration or cyber security can have marketwide consequences.
We support mandatory minimum standards, registration with TPR, and orderly exit frameworks that protect members and reduce systemic risk — with expectations scaled proportionately to the size and complexity of the administrator involved.
3. DB endgame readiness and data assurance
As DB schemes approach key endgame milestones, highquality data becomes essential.
We highlight the need to encourage prebuyin/buyout data audits, clear allocation of responsibilities between trustees, administrators and insurers, and stronger transactionreadiness standards to avoid rectification exercises and ensure accurate member benefits.
4. Professionalisation without losing the member voice
We support statutory accreditation, clear competence standards and enhanced CPD for professional trustees.
At the same time, lay trustees continue to offer valuable perspective. Their contribution should be supported through modernised training tools, flexible CPD and structured mechanisms such as member panels and integrated memberfeedback loops. Professionalisation must not dismantle the member voice — it should modernise how that voice is heard.
5. Earlier and more decisive regulatory intervention
As schemes consolidate, governance weaknesses can have broader consequences.
We advocate giving regulators clearer, triggerbased powers to intervene earlier — including directing professional trustee appointments, requiring data audits and strengthening oversight of vertically integrated models.
Putting proportionality at the heart of reform
Throughout our response, we emphasise that governance expectations must be proportionate.
Megafundscale schemes should meet institutiongrade requirements; smaller schemes should retain flexibility and avoid disproportionate burden. Proportionality is essential to preserving competition, supporting innovation and ensuring that reforms uplift the system without overwhelming it.
Our full submission
Our response sets out a practical, futureproofed framework for strengthening governance, building trustee capability, improving data assurance and ensuring the system remains safe, resilient and effective for savers.
