Hello and welcome to our Master Trust Bulletin.

As 2025 draws to a close, now is a good time to reflect on significant policy developments and milestones, as we look to the year ahead.

Our annual Defined Contribution (DC) Scheme Survey, published in the autumn, showed 98% of master trusts are supporting around 27 million members with their retirement decisions, ahead of the upcoming duty to offer default retirement products to members.

As with the guided retirement duty, master trusts will continue to lead the way. They are increasingly central to delivering secure retirement outcomes for millions of savers. Strong governance has never been more critical as master trusts seek to implement initiatives including guided retirement, small pots and investments in private assets over the coming years.

Alongside the Pensions Bill, key development areas for master trusts and the wider market include:

• Pensions Dashboards Programme: full connectivity and data readiness will be a major focus as dashboards move closer to launch.
  
  
• Climate and sustainability reporting: continued emphasis on integrating climate risk into investment strategies and meeting disclosure obligations.
  
  
• Investment governance: heightened awareness on ensuring governance and risk management evolve in step with increased allocations to private markets.
  
  
• Individual transfer market: master trusts are experiencing increased member-initiated transfer activity. Higher levels of member engagement is a positive, however there are concerns some members may not be making a fully informed choice, and increasing activity is also highlighting potential inefficiencies and frictions in how transfers are handled.
  
  
• Reserving requirements: engagement on, and changes to, regulatory capital guidance and longer-term legislative considerations. 

Update on our reserving review

I also want to take this opportunity to provide a brief update on the reserving review. We pledged to undertake this as part of the government’s wider approach to supporting growth in the UK economy, with the aim of assessing whether it is possible to safely free up capital for scheme funders to reinvest.

We have now completed a detailed internal review of reserving approaches and market trends since authorisation. The master trust market has matured considerably: the number of schemes has reduced, average scheme size has grown significantly, and most schemes are now profitable with well-established governance and risk management frameworks. Our experience of consolidations and market exits in recent years has also informed this review. 

The initial findings highlight:

• areas of prudence in our guidance that could be safely relaxed to reflect the current maturity of the market,
  
  
• behaviours by some master trusts that add further prudence and push up reserves unnecessarily, which could be addressed through greater awareness of best practice and alternative approaches, and
  
  
• a need to consider longer-term changes to legislation and the Code to reflect a market that will consist of large-scale schemes by 2035.

We are now engaging with the industry throughout this month and into early next year to share findings and seek views on appropriate changes. We will communicate the outcome and updated guidance early in 2026. 

Planning ahead

I know from my discussions with many of you that planning for next year is already in full swing. Looking ahead can feel daunting when considering the number of policy areas to be progressed and the challenge of how best to align resources and the phasing of investments in response to this. However, as we have seen over 2025, the best progress comes when there is an open and constructive working relationship between government, industry and regulators, with a clear focus on outcomes for savers. We look forward to our ongoing work with you next year, as we continue to refine and embed updated approaches to governance, investment, data quality and the saver experience.

A lighter note

On a slightly lighter note, I’d also like to thank those of you who responded to our recent survey seeking your thoughts on the Master Trust Bulletin. From your feedback, we know the bulletin is increasingly a key channel for staying up to date with developments across master trusts and pensions more broadly. We always keep our communications under review and will continue to ensure the bulletin remains an excellent source of information that is visually appealing and easy to navigate. We hope you find this latest edition interesting and informative.

TPR celebrates dashboard connections

We congratulate all schemes that have already connected to dashboards, recognising the significant progress in recent months. More than 60 million member records are now connected - that’s three-quarters of private pension records in scope, as well as tens of millions of state pension records.

 
Building on this momentum, the focus for larger schemes now shifts to post-connection duties. This includes meeting exacting data standards and ensuring operational readiness before dashboards are launched to the public.

Updated data quality guidance and deep dive engagement

With data at the heart of dashboards, so that the right information is returned to the right savers, we have strengthened our scheme member data quality guidance (formerly known as ‘record keeping’ guidance) and brought all our data-related guidance into one place.

The update, which was published last month, emphasises that member data is a strategic asset, and trustees should take an active role in data management. The guidance also aligns with the government’s six dimensions of data quality, which go beyond accuracy and completeness.

We are committed to continuing to work with industry to understand data management in practice and support as we need to. In line with this, we have also launched a deep dive engagement focused on the data quality controls and dashboards data preparations of the UK’s 51 largest schemes. Collectively, this covers more than 80% of our regulated dashboards memberships. Most of these schemes have now been engaged through questionnaires and meetings, but our work will continue into the new year, when we will share our findings.

Miss our winter webinar?

Recently, we held a webinar to support the next wave of connections. Over 1,000 industry professionals registered for the event, which included a 35-minute live Q&A.

Thank you to everyone who attended and contributed. The event featured valuable insights from industry experts, including representatives from the Pensions Dashboard Programme (PDP), Pensions Administration Standards Association (PASA), and Vidett, a professional trustee firm, which proved highly informative for all participants.

New industry-facing video launched to support schemes to be operationally ready

The Money and Pensions Service (MaPS) has just launched the first of a set of videos they have produced specifically for industry. These videos offer a demonstration of what the MoneyHelper Pension Dashboard looks like during phase one of consumer testing. From illustrating the identity verification process, to showing industry how savers will see their pensions displayed, these resources will be extremely valuable for schemes in briefing their operations teams.

We recommend that schemes watch and share this video internally, but it is very important that we limit the community we are sharing the video with to those involved in, or impacted by, testing and we ask that you do not publish the videos or share them with members or consumers.

Post-connection duties

We have contacted schemes that have successfully connected to pensions dashboards – and are in good position to be well prepared in advance of the final deadline of 31 October 2026.

If your scheme is one of ‘the connectors’, it is vitally important to take note of your ongoing duties – including maintaining connection.

Other post-connection duties include:

• data quality management - including delivering any outstanding data improvement or data digitisation actions
  
  
• adapting to change - including using insights from MoneyHelper dashboards' user testing to identify improvements needed to your data and processes so you can be ready for public launch
  
  
• keeping on top of updates - including receiving regular reports from your connection provider and administrator on dashboards implementation and signing up to all relevant news sources – including PDP’s newsletter.
  

AI: The Potential for members to be influenced

The use of Generative AI tools such as ChatGPT, Gemini, Claude or Microsoft 365 Copilot has grown rapidly and there is growing evidence that individuals are using these to support financial planning including pensions planning.

Doing so is however not without risk.

 
Our investment team asked questions of Generative AI tools with this focus on financial planning. Whilst not a rigorous experiment, we found the output could appear impressive due to the speed, polish and presentation but this could hide significant limitations and omissions. Whilst we also recognise that results vary based on how questions are phrased, and which tools are used, we are concerned about the potential for savers or schemes to be inappropriately or insufficiently informed if relying on them.

AI applications will continue to develop, evolve and improve at a rapid pace and the AI tools will mature, and their responses will improve. However, members who lack awareness of the risks and limitations and lack sufficient experience and knowledge to ask AI the right questions and challenge the responses appropriately could end up making inappropriate decisions about their pension arrangements and receiving poorer outcomes.

Having spent many years helping members to build their pension savings, trustees, with support from their advisers, could consider whether it would be appropriate to include some additional risk warnings in scheme documentation and member communications on the use of generative or other AI applications to inform decisions about their pension arrangements.

AI is a transformative technology with significant opportunities for schemes and members. AI offers great opportunities for members, but needs to be used responsibly, keeping front of mind the mantra of “cautious, but curious”, to improve outcomes for members whilst maintaining trust and compliance.

Vote reporting: Another step forward by industry

In October 2020, the PLSA published the first version of the Vote Report Template to help trustees with the new voting disclosure elements required as part of implementation statements produced on or after 1 October 2020.

In November 2022, in response to the Taskforce on Pension Scheme Voting Implementation Report, the FCA established an industry wide Vote Reporting Group to develop detailed proposals to enhance shareholder vote reporting in the UK in order to address shortcomings identified by the report.

 
In March 2025, Pensions UK published an updated Vote Reporting Template which was based around the core VRG proposals and complemented by some relevant elements of the previous PLSA template. In September 2025, in a further update, Pensions UK published Technical Guidance to support users of the template alongside some minor updates to the template. They are aiming to embed the template across the asset management industry from early 2026.

In practice, the template should lead to:

• better and more consistent vote reporting
  
  
• lower reporting burden (and costs) for asset managers and trustees
  
  
• more transparent voting activities - which should also help to improve alignment between trustees’ stewardship objectives and investment managers’ stewardship activities
  
  
• better outcomes from higher quality engagement
  
  
• trustees having a better understanding of key shareholder votes made by their investment managers
  
  
• trustees being better able to hold their investment managers to account for their voting practices.

The further development of the Vote Reporting Template, by industry, for industry is a positive development. It should enable trustees to get more standardised, comprehensive and granular information from all their investment managers on a consistent basis. This should help to streamline the preparation of implementation statements for trustees. While completion of the template is voluntary, trustees should ask their investment managers for the template to be completed.

DC fund illustrations

In our December 2024 Bulletin we highlighted that trustees of eligible schemes must produce DC fund illustrations for two different purposes using:

• AS TM1: Statutory Money Purchase Illustrations. published by the Financial Reporting Council to calculate SMPIs
  
  
• either ASTM1 or the FCA’s Conduct of Business Sourcebook (CoBS) to illustrate the cumulative effect of costs and charges on the value of a member’s pension pot over time, as part of the chair’s statement

As outlined in that Bulletin, paragraph 11 of DWP’s statutory guidance currently refers to trustees using the assumptions in AS TM1 (version 4.2), published in October 2016, and the FCA’s Conduct of Business Sourcebook (CoBS) as at 12 April 2021.

The DWP has confirmed that:

• Schemes can voluntarily use the most recent version of AS TM1 or CoBs, published by the FRC or the FCA respectively, appropriate to the period for which the illustrations in the chair’s statement are being prepared. 
• In line with Paragraph 12 of its statutory guidance, it intends to consult in the future to maintain alignment with their guidance.

Trustees should also note that:

• The Financial Reporting Council launched a consultation on AS TM1 v5.2 on 30 October 2025. That consultation did not propose any amendments to the assumptions in the standard, however, it included a minor wording amendment relating to fund volatility calculation dates to clarify policy intention. Following the consultation, it aims to publish the final AS TM1 by 15 February 2026, for application in the following financial year.

• The FCA has revised the assumptions underlying CoBs, since the date (12 April 2021) referenced in the DWP guidance.

Administration: updated guidance and insight

We recently published updated guidance to help trustees and administrators deliver high-quality services that safeguard member benefits and build trust in the pensions system.

The guidance consolidates all administration expectations for trustees and administrators. It provides practical steps for governing bodies to ensure high-quality administration that meets regulatory expectations, replaces previous Administration of a DC Pension Scheme guidance and applies to all scheme types.

The guidance comes at a pivotal moment for the pensions industry. Administration is now recognised as a critical driver of good outcomes for savers. Insights from our recent market oversight report highlights progress and persistent challenges around governance, technology, data, and resilience. With increasing regulatory change, rapid technological transformation, and rising member expectations, the role of administrators has never been more important.

Best practice we have seen

The guidance follows recent engagement with administrators which highlighted good practice around technology and innovation, cyber resilience and workforce development.

 
Technology and innovation

Our engagement showed administrators are investing in technology, automation and artificial intelligence (AI) to streamline processes, reduce errors, free resources for strategic work, and enhance members’ experience. Best practice we saw includes having a technological road map which clearly sets out objectives and key milestones. Examples of key initiatives are platform consolidation, AI automation to streamline administration process, tailored member-facing tools (for example portals, apps, biometric ID), and responsive service models, such as vulnerable member teams.

Cyber resilience

Our engagement also highlighted that administrators recognise the need for robust cyber security, and some have strong testing routines and senior-level oversight. Good practice we saw includes:

• cyber risk integrated into risk framework
  
  
• business continuity and incident response plans tested annually
  
  
• multifactor authentication, encryption, and continuous monitoring
  
  
• supplier assurance frameworks with penetration testing.

Workforce development

In respect of workforce development, we observed that administrators are addressing the challenges in recruiting and maintaining skilled staff. Good practices we saw include training academies, career pathways, accurate forecasting and cross-training for peak demand.

Trustee engagement

Our engagement also highlighted that trustee engagement varies. Good examples we saw include collaboration with administrators on service delivery, joint oversight of data quality and cyber risk, and shared Key Performance Indicators.

Looking ahead

Trustees and administrators should review their practices, work together, leverage technology, and strengthen resilience to raise administration standards.

 
For more information, read our updated guidance and Market oversight report: Administrator relationships.

Outcomes based regulation

Since 31 July 2023 all FCA authorised firms providing products or services have had to comply with the Consumer Duty where they can materially influence ‘retail customer’ outcomes. The Consumer Duty is based on four key elements which drive good outcomes, these are:

• products and services – which should be designed to meet customer needs
  
  
• price and value – which should enable consumers to receive fair value
  
  
• consumer understanding – which should enable consumers to make informed decisions
  
  
• consumer support – which should meet customer needs throughout and enable them to pursue their financial objectives.

The Consumer Duty did not impose any compliance or other obligations on trustees of occupational pension schemes. However, the FCA has been clear that for FCA regulated firms they expect:

• products or services provided to trustees of occupational pension schemes to be in scope
  
  
• members of those schemes to be treated as ‘retail customers’
  
  
• activities that can have a material influence on member outcomes for example, member communications, to be in scope

In September, in response to a request from the Chancellor to assess the impact of Consumer Duty in relation to wholesale activity, the FCA set out a four-point action plan, which included that, in the first half of 2026, it would: “… Consult on changes to rules on the application and requirements of the Duty, including through distribution chains…to make it clearer for firms where the Duty applies and … when it doesn’t. …” Following consultation in 2026, the new requirements are likely to come into effect in 2027.

 
Improving the Quality of Fund Disclosures

In a review published in November 2023, the FCA found evidence of some good practice in the design and delivery of ESG and sustainable investments, but in some instances they found the disclosure principle had not been fully embedded. This meant, for example, that:

• key ESG and sustainability information was not often presented in a coherent and accessible fashion, making it harder for investors to understand key features
  
  
• sometimes further ESG and sustainability-related information was included in supplementary reports which weren’t always clearly identified
  
  
• some disclosures lacked key ESG and sustainability related information that members would find helpful

On 28 November 2023, the FCA set out their final rules and guidance to help consumers navigate the market for sustainable investment products. Trustees of occupational schemes were not directly impacted by the new requirements, but some investment funds used by their schemes may have been impacted.

Managing Occupational Scheme Fund Disclosures

For trustees of pension schemes getting the balance right in the level of disclosure in member communications has often been a practical challenge, for example:

• Fund names can sometimes be simplified in booklets or on scheme provider platforms to avoid complexity for members or to simplify future fund substitution. For example, a Low Carbon fund category could include a range of funds that are Paris Aligned, Transition Pathway aligned or that include specific exclusions, such as, fossil fuels.
  
  
• Some providers may sometimes only provide limited information, like Fund Factsheets, on the scheme platform landing page, with more detailed information, for example, on ESG features, provided through some obscure links or embedded in lengthy terms and conditions.

Trustees should be aware that simplifications, though well intentioned, can sometimes give rise to challenges from members and potential claims around greenwashing unless the disclosures are clear. For example,

• a Low Carbon fund does not necessarily mean a low carbon ‘now’ fund
  
  
• headline fund decarbonisation targets can often only be based on Scope 1 and Scope 2 emissions, when the majority of the fund’s carbon footprint may be based on Scope 3 emissions
  
  
• material stock positions in individual high emitter stocks may be included in some low carbon funds

We would recommend that trustees ask their service providers to confirm:

• how the Consumer Duty applies (if at all) to the products or services they supply to the scheme
• whether and how the FCA labelling and disclosure requirements apply to any of the investment funds they provide to the scheme and; where relevant
• whether any member communications provided (platform based or otherwise) are compliant with the Consumer Duty
• how they monitor outcomes and ensure compliance on an ongoing basis

Where trustees have tailored the materials available to members, they should be fair, clear and not misleading and support and enable members to make informed decisions.

Significant Event J considerations

Next year we plan to publish further guidance on significant events. This is in response to calls from schemes for more clarity about when to report a significant event J. As a reminder, a significant event J is where there has been a failure of the systems or processes used in running the scheme which has a significant adverse effect on the security or quality of data or on service delivery. There is a duty to report to us any significant events in writing so we can consider any impact on whether the scheme continues to meet the authorisation criteria.

We often hear schemes refer to the percentage of members affected as being the core consideration to whether an event should be reported to TPR. As schemes have grown, this is not always the most useful or relevant metric to use and can detract from the impact experienced by those members affected.

While scale of impact is important, it should not be considered in isolation. The event should be considered in the round when assessing whether it has had a significant adverse effect including whether the member/s have suffered financial detriment or non-financial detriment (e.g. inability to access member information or provision of inaccurate information). Our guidance lists examples of events that should be reported to TPR and we recommend that you refresh yourselves on these.

The duty to report significant events falls on trustees, scheme funders, strategists, advisers and administrators involved with the scheme, and so it is important that schemes have processes in place as to who will report significant events, and when.

It will be important for the scheme to seek its own legal advice on whether an event is reportable to us. We would encourage you to speak to your supervisor if you have any concerns and to use our SE J form which is currently being refreshed and will launch on our website shortly.

Trustee toolkit update: Revised content and next steps

We are in the process of reviewing and updating the Trustee Toolkit to ensure it continues to provide trustees with accurate, accessible, and engaging learning content that reflects the latest regulatory and legislative developments.

Several modules have already been refreshed and are available in beta, including:

• Introducing Pension Schemes
  
  
• The Trustee’s Role
  
  
• Running a Scheme
  
  
• Pensions Law
  
  
• How a DC Scheme Works

These beta versions feature updated content, improved accessibility, and refreshed graphics. Trustees can access them by logging into the toolkit as usual, navigating to the relevant module, and selecting the link at the top of the page to view the beta content. Users are also invited to share feedback via a form available on each beta course page.

Work is underway on the defined benefit and investment-related modules, with the first beta versions expected to be released early next year. While the content is being updated, the core structure of the toolkit and the way users access and complete modules will remain the same.

The Trustee Toolkit remains a key resource to help trustees of occupational pension schemes meet the minimum level of knowledge and understanding required by law.

Strengthening investment governance: A call to action for pension schemes

As pension schemes navigate an increasingly complex investment environment, the importance of robust governance and risk management frameworks cannot be overstated. With regulatory expectations rising and market dynamics shifting, trustees must ensure their schemes are equipped to make informed, resilient decisions that protect member outcomes.

Investment governance frameworks: defining clarity and accountability

A well-structured investment governance framework provides clear roles and responsibilities for all stakeholders across every stage of the investment process, from strategic decision-making to implementation. This clarity helps to:

• avoid duplication and gaps in oversight
  
  
• ensure accountability across advisers, managers, and fiduciaries
  
  
• support consistent and transparent decision-making

By formalising governance structures, schemes can better align their investment activities with long-term scheme objectives and regulatory expectations as well as identify potential conflicts of interest that need to be managed.

Investment risk frameworks: understanding and managing risks

An investment risk framework complements governance by offering a comprehensive view of the risks inherent in a scheme’s investment strategy. As investment strategies become more sophisticated, with increasing allocation to private markets and implementation of decumulation strategies, a visual investment risk dashboard can be a powerful tool for trustees. It should include:

• a detailed list of investment risks including market, credit, liquidity, operational, and ESG/climate-related risks
  
  
• the potential impact of each risk on member outcomes
  
  
• mitigation strategies and controls
  
  
• assigned responsibilities for monitoring and managing each risk
  
  
• reporting requirements to ensure transparency and timely escalation

This framework enables trustees to make proactive, informed decisions and respond effectively to emerging risks, particularly in scenarios such as scheme consolidation or changes in investment strategy.

Next steps for trustees

We encourage pension schemes to:

• review and update their investment governance and risk frameworks
  
  
• engage with advisers to benchmark against best practices
  
  
• ensure frameworks are dynamic and adaptable to future challenges

By taking these steps, trustees can strengthen their oversight, enhance resilience, and ultimately safeguard member outcomes

Navigating market volatility

Master trusts are inherently exposed to market volatility and navigating this requires robust investment governance.

Current global conditions continue to shape a complex and fast-evolving landscape. The Bank of England and the IMF have recently warned of downside risks in the face of concerns about price appreciation in the tech sector, concerns about private credit, and wider political instability.

As part of good governance, trustees should understand the risk exposure of underlying investments and assess the potential impact of adverse market movements for different groups of members. An investment risk dashboard, as discussed in the story above in this bulletin, is a useful tool to do this. Trustees should also regularly review the arrangements to ensure they remain suitable and reflect a range of possible opportunities.

Should market volatility arise, we expect trustees to maintain high standards of governance and risk management to respond to volatility and adapt to changing conditions. Our recent guidance highlights key actions trustees should consider during periods of market volatility:

Member communications

Short-term market losses can prompt members to switch funds, potentially locking in losses. Trustees should monitor member activity, provide clear guidance on market impacts across different cohorts, and encourage members to seek advice before making changes. Raising awareness of scams is also essential during periods of market stress.

Investment and risk management

Trustees should review rebalancing arrangements, diversification levels, and the appropriateness of planned transitions in light of volatile conditions.

Strategic oversight

Investment markets often change, especially after market turbulence. Trustees should work with their advisers to assess the ongoing suitability of the investment strategy and how it might evolve in the future.

For further guidance please see Market volatility and what trustees should do.

Considerations when implementing structured equity solutions

As investment strategies evolve, we are aware that some providers are restructuring physical passive equity portfolios into more complex arrangements, typically involving a total return swap.

These arrangements aim to reduce investment fees, potentially allowing for allocation to more costly asset classes, however they can also introduce additional layers of complexity and risk. Trustees should evaluate whether the anticipated benefits justify the operational and strategic challenges involved and acknowledge the potential lack of transparency intrinsic in these solutions.

Here we outline key areas to consider when exploring these types of investments.

Knowledge and understanding risk

 
Structured equity solutions introduce additional risks compared to physically held equity (such as counterparty, operational and roll risk) and potential implications to trustee’s stewardship policies. Trustees and providers should have a clear understanding of the structure, mechanics, costs, and associated risks of the strategy, including the implications for returns under different market conditions and the roles and responsibilities of all parties involved. A dedicated risk framework, where all risks are mapped with their respective mitigation/monitoring approach, is also a good practice.

Governance and ongoing review

A robust governance framework is important, supported by sufficient resource and expertise. Trustees should implement processes for ongoing review of performance, risk exposures, and alignment with scheme objectives.

Transparency and member communications

Structured equity solutions can be difficult to understand and explain to members. Trustees should consider how best to communicate the nature of these investments, and their underlying exposures, for example in the context of climate-related disclosures for TCFD reporting.

Early engagement encouraged

Trustees play a critical role in safeguarding member outcomes. As investment strategies evolve, proactive oversight and informed decision-making are more important than ever. We welcome early engagement from master trusts considering these solutions so that risk management can be considered against the potential benefits of such solutions, ahead of implementation.

As with any new opportunity, we remind trustees of the need to ensure investments are permitted by the Trust Deed and Rules, to seek appropriate investment advice as set out in section 36 of the Pensions Act 1995, and to review their Statement of Investment Principles to include the new risks associated.

Defence investing: Repositioning needed

As geopolitical risks have increased in recent years, so too has recognition of the need for a significant increase in government budget spend across NATO nations. In the UK, defence currently supports nearly half a million jobs, with around 2.2% of GDP being spent on defence. This is now expected to increase in stages over the next 10 years, rising to a core commitment of 5% of GDP in 2035, with 3.5% being allocated for core defence and 1.5% for national resilience and security.

Published in September, the UK Government’s Defence Industrial Strategy 2025 developed the case for defence as one of the eight priority sectors in the government’s Modern Industrial Strategy. This strategy will be further supported by the forthcoming defence investment plan, which is expected to set out key investment priorities, together with an outline of procurement demand to give investors the confidence to invest.

Significant opportunities for investment (in the UK and overseas) across a range of listed asset classes and private markets, including private equity, venture capital, infrastructure, real estate and debt are likely to arise.

For many schemes, investing in defence has for many years been part of business as usual, subject to some key exclusions, typically around controversial weapons. For others it has been much more challenging. In addition, fears about reputational risk, the potential for negative press headlines, member challenge and concerns over ESG credentials, have often either limited or restricted consideration of defence investments.

As with investment opportunities in other areas, we would encourage trustees to develop their understanding of the range of investment opportunities that might exist here.

 
Trustees, with support from their advisers could:

• review the range of opportunities for investment in defence
  
  
• consider developing a set of specific investment beliefs for that sector
  
  
• review any current exclusions on fund mandates and consider whether they are consistent with their investment beliefs
  
  
• monitor mandate exclusions for any unintended consequences /stock omissions
  
  
• consider, if appropriate, developing member communications which explain the broader investment case for investment in defence

A recent report from the Royal United Services Institute, sponsored by the UK Sustainable Investment and Finance Association concluded: “ESG disclosure and labelling regimes, as well as many investors’ own ESG investment approaches, generally do not preclude financing and investment in defence”. However, defence-specific exclusions on some fund mandates may exclude individual stocks or sectors. This is another factor for careful consideration. In an increasingly centralised, connected and data dependent world, the protection of critical infrastructure and critical services is key, and the steps that governments and industry take to address this may create a range of investment opportunities.

Join our roundtables to help shape our future work

Your experience and insight can help shape our work on the future of trusteeship and scheme governance.

We are holding a series of roundtables early in 2026 to discuss ways of improving the quality of trusteeship and governance.

 
The sessions will be facilitated by challenging questions and practical suggestions to prompt candid discussions and innovative thinking which will help inform our future regulatory approach.

More information about roundtable dates, the attendee selection process and how to express your interest are available in our online form on our website.

Consolidation – are you taking on smaller schemes?

We are keen to hear from master trusts interested in being involved in a case study about taking on smaller schemes. Lessons learned and best practice examples would be used as part of planned additional guidance for trustees of smaller schemes seeking to consolidate into master trusts.

The call for insight follows an earlier request in the July MT bulletin to speak to master trusts taking on smaller schemes as part of their consolidation plans. Here, we share our early insights from these conversations.

To date, we have heard about:

• innovations being used to attract trustees of smaller schemes
  
  
• perceived barriers for trustees of smaller schemes wanting to consolidate into master trusts
  
  
• opportunities to enhance current TPR guidance

Please speak to your TPR supervisor if you have not yet spoken to us and you are keen to share your experience and insight in this area, and your views on how we can help the industry to overcome challenges and barriers.

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