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The Pensions Regulator


Master Trust

Bulletin

Welcome to the September Master Trust Bulletin

FOR ACTION 


Enabling UK productive finance through private market investments


Look out for our updated significant event J guidance


Updates to scheme financial template – new guidance 


What pensions reform means for master trusts – our next event  


All the latest - pensions dashboards



ESSENTIAL READING


Governance & Trustee Practice


Future-proofing trustee boards

Enhancing administration reporting - insights and best practice  


Manage your cyber risk from emails 


Trustee board and committee observations – good practice 


Inheritance tax reforms - further preparation guidance


Investment & Member Outcomes


New publication reveals how master trust default assets are invested

Bank of England's Private Markets System-Wide Exploratory Scenario Exercise: Round 1 launch


Too hot to grow 


Transfers and transactions 


Individual member transfers out – TPR engagement


Members with guaranteed benefits transferring to master trusts - case study

 

Ben Gunnee

No cooling off for pensions reform, governance and investment - Ben Gunnee, Executive Director, Market Oversight


Hello and welcome to this month’s Master Trust Bulletin. After the extended heatwave, I am pleased to experience some cooler temperatures. However, at TPR things continue to ‘heat-up’ and work continues at pace on both the implementation of the Pension Schemes Act 2026, and our continued focus on a prudential, no-surprises, regulatory approach.


I have now been in post for around six months, and I can hand on heart say this is the most interesting role in my career to date. I joined the regulator with close to 25 years’ experience in the investment industry, much of it spent with Mercer. I also qualified as an actuary more than 20 years ago.


In my role as Executive Director of Market Oversight, I have leadership and decision-making responsibilities across a wide range of industry participants including master trusts, single employer defined contribution, defined benefit, collective defined contribution, superfunds, administration as well as wider governance including trusteeship.


I have been really pleased to see the depth and breadth of experience within the team and strong, two-way relationships that have formed across supervised master trusts. The team continues to make good progress on key areas of the new legislation, including the centrepiece value for money framework. Thank you to all those that responded to the latest consultation which closed on 15 September. Many of you will have noticed the consultation included several amendments to the proposed framework as a direct result of industry feedback, and we look forward to completing our review of the latest submissions and reporting back on any further refinements.


While there is a lot of change and new development, we continue to be very focused on business-as-usual activities. Two areas to highlight where there have been active internal discussions are governance and investment, particularly the role of private markets within investment portfolios. As the asset size of the master trust market continues to grow, we are keen the governance of schemes continues to reflect the scale and complexity of their offering – and we expect trustees and those that support them to have the right skills and knowledge to deliver good outcomes for members.


For private markets we are pleased to see more emphasis on how they can be incorporated into an investment portfolio, and a move away from an overall cost focus within the investment portfolio to a value for money approach. Following our engagement with the industry earlier this year we recently published our findings, and you can read more about this in this bulletin.


This edition also provides a number of good practice examples we have seen from schemes including boards using clear committee summaries, effective service reporting and robust Service Level Agreement (SLA) data. The market is entering a period where reform, growth and operational change are all accelerating, so trustees need to stay focused on strong governance, member outcomes and readiness for change, not just compliance.

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What pensions reform means for master trusts – our next event


Pensions UK conference fringe event for master trusts


We’re looking forward to seeing many of you at our fringe event for master trusts, taking place just before the Pensions UK Annual Conference in Liverpool on 13 October 2026.


We will be joined by colleagues from the Financial Conduct Authority to discuss what pensions reform could mean for master trusts in practice. Together, we’ll share how we’re working closely to support implementation, provide a consistent regulatory approach, and help schemes prepare for the changes ahead.


There will be plenty of opportunity to ask questions, share feedback and hear directly from both regulators.


If you have any questions about the event, or you’re unsure whether your organisation has received or responded to the invitation, please contact us at events@tpr.gov.uk and a member of the team will be happy to help.

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Enabling UK productive finance through private market investments


We have published a report showing pension schemes want to invest in private market assets, but are facing barriers including capability and knowledge gaps, fees and a lack of suitable investment opportunities.


Our market oversight report follows engagement we carried out last year with more than 40 industry stakeholders to try to better understand the barriers, challenges and opportunities that schemes face around investing in private markets.


As set out in the report, private market assets can offer trustees the opportunity to access a wider range of investments with the potential to deliver improved outcomes for their scheme’s members.


Looking ahead, the range of private market investments available to trustees is expected to increase further. For example, the UK government’s commitment under the Mansion House Accord to develop an investible pipeline of assets for pension funds may create additional opportunities. Effective implementation will therefore be key to managing the opportunities and risks associated with these investments. This will include building an effective portfolio of private market investments across asset and sub-asset classes running over both years and market cycles. As such, three of the key issues for trustees to consider are:


Focus on member outcomes


The potential value and improvement in member outcomes that investing in private market assets could offer should be a key consideration.


Ensure access to the right level of investment and risk management skills


Both individually and as a board, trustees should have sufficient skills and expertise to enable them to consider the full range of private market investment opportunities, and how those investments might be most efficiently made. Trustees should also ensure that they have access to sufficient investment support, including external independent investment advice.


Ensure appropriate governance and risk controls are in place


Trustees should have a robust policy and risk management framework for their private market investments in place. Trustees should also have considered how their governance and investment management structures might need to evolve as their scheme gains material asset scale.


Insight from our engagement has been very helpful in developing our thinking around policy and supervision, as aspects of the pensions reform agenda and expectations around pensions and growth have developed. The findings have also been helpful in our engagement with the DWP and other key stakeholders and we hope our insight will support further constructive discussion between trustees, industry, government and regulators.


We are very grateful to those stakeholders who engaged with us and provided their views.

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Look out for our updated significant event J guidance


A significant event J is 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.


In response to industry feedback requesting additional clarity on what constitutes a significant event J, we'll be publishing updated guidance later in the autumn.

Our new guidance will give more clarity on what constitutes a significant adverse effect. In addition, to help you decide if and when you need to report an event to us, the guidance will include a new traffic light system. We provide illustrative examples of what constitutes a red, amber or green event.


Our updated significant event J guidance and forms will be published on our website next month.

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Updates to scheme financial template - new guidance


Following the publication of our guidance on Master trust capital reserving requirements earlier this year, we have made some minor updates to the Scheme Financial Template (SFT) for submissions made from 1 September 2026 onwards.


DC master trust schemes should ensure that the revised template is incorporated into their sign off and reporting processes ahead of their next SFT submission.


The updates are designed to improve clarity within the reserving section and facilitate the publication of annual data on reserving in 2027. We have also streamlined other sections of the SFT and details on the key changes are set out below.


Financial Reserves


Schemes will now be asked to provide haircut values against the asset categories used for reserving. Haircut calculations should continue to be included within the business plan/costs assets and liquidity plan (CALP).


Income categories


We have streamlined the categories to include the following:

  • charges on assets under management or administration (annual management charge)
  • fixed rate charges paid by members
  • charges paid by participating employers
  • public service obligation offset payment
  • all other income

New fields


We have added the following fields:

  • SFT reviewer
  • the hypothetical triggering event date

Information no longer requested in the SFT


We have removed information requirements for:

  • AE opt out percentage assumptions
  • annual investment return assumption
  • forecast member and employer communication and cost details

If you have any questions regarding completion of the SFT, please contact your usual TPR supervisory contact.


Read our SFT guidance which has a link to the updated template.

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All the latest - pensions dashboards

New regulatory initiative coming soon - industry operational readiness


With the 31 October 2026 connection deadline approaching, our focus is on the next key milestone: the launch of the MoneyHelper dashboard.


To help government understand how operationally ready schemes are for launch - we are reaching out to a selection of schemes (including some master trusts) and administrators, asking them to complete a questionnaire covering operational planning, testing, resourcing and governance.


This will help inform industry’s readiness and any further support or information needed from The Pensions Regulator or the Money and Pensions Service (MaPS) to prepare for launch.


We recognise that operational planning for dashboards may not yet be complete and will continue to be informed by the results of testing, the announcement of the launch date and other relevant factors.


A second phase of engagement is planned for early 2027, when we will follow-up on how plans have been implemented and refined.

Watch our webinar and be ready for what’s next


On 8 July, several hundred pension professionals joined our final webinar before the 31 October pensions dashboards connection deadline.


If you missed it, or want to watch it back, the full recording is now available on our website.


We're all on a shared journey of learning and we hope the insights and learnings will give you greater confidence and clarity around post-connection responsibilities.

Watch our webinar

New industry-facing MHPD walkthrough videos published


We are delighted to share the second iteration of a set of walkthrough video demonstrations of the end-to-end MoneyHelper Pensions Dashboard user journey as it looks currently.

To support training, the full-length video has been split into three smaller videos:

  • Part 1 of 3: Identity verification and logging in (3 mins 47 secs)
  • Part 2 of 3: Information summary and confirmed pensions (5 mins 51 secs)
  • Part 3 of 3: Pending pensions and those needing user action (2 mins 52 secs)

This new iteration reflects the changes that have been made to the dashboard since the first videos were released in November 2025, thanks to valuable insights gained from user research.


While Master trusts will be well progressed with operational planning, these new videos should be used to update operational teams on the steps consumers go through when using the dashboard. This will help schemes and providers accurately prepare for future member queries based on the latest information.


As testing progresses, the MoneyHelper Pensions Dashboard will continue to evolve in response to learnings from testing. This means these videos are current at the present time but there are likely to be further changes to the dashboard before it is made available to the public. With this in mind, we will limit the community they are sharing the videos with to those involved in, or impacted by, testing and we ask that you do not publish the videos or share with members/consumers.


We hope you find them useful. Further changes to the dashboard will be informed by user testing so the Money and Pensions Service are not seeking direct feedback from industry on the version shared in these videos. However, if you do have any specific queries or comments you can raise them via PDP Support.

Watch the full-length video

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Future-proofing trustee boards


In the July bulletin we emphasised that the operating environment for master trusts continues to evolve at pace. Regulatory expectations, market complexity and growing member needs are reshaping what effective governance looks like in practice. Against this backdrop, trustee boards must ensure they are not only effective today but fit for the future.


Rethinking the trustee skills matrix


A well-constructed skills matrix remains central to trustee board effectiveness. There is a risk that schemes continue to rely on frameworks that no longer fully reflect the breadth of expertise required in today’s, and tomorrow’s, environment.


Through our supervisory work, we have seen skills matrices that focus predominantly on traditional disciplines such as investment and core governance and do not sufficiently capture evolving or specialist areas, including:

  • cyber and data security
  • ESG and stewardship
  • decumulation and retirement journey design
  • member engagement and behavioural insight
  • operational resilience and service provider oversight

We have also seen a lack of clear definitions on proficiency, making it difficult to distinguish between basic awareness and deep expertise.


If the skills matrix is outdated it limits the board’s ability to identify gaps, target training effectively, and plan future recruitment.


To address this, it is recommended that trustee boards:

  • Reassess their skills framework against current and emerging requirements.
  • Introduce tiered proficiency levels (for example awareness, working knowledge, specialist expertise).
  • Undertake an honest evaluation of current capability.
  • Align identified gaps with future strategic priorities.

This should be a living document, reviewed periodically and updated, as a minimum, following any changes to board composition or regulatory expectations.


The growing demands on trustee boards


The role of a trustee has evolved significantly. It is no longer simply about oversight and also requires active engagement, challenge, and accountability.


Our recent stakeholder survey (which did not cover the entire master trust market) found that the average master trust board size is 6.7 members. While there is no prescribed number of trustees and board composition should always reflect scheme-specific circumstances, the capacity of the trustee board must be considered alongside the increasing volume and complexity of work. The smaller the board the higher the concentration risk, making board effectiveness and resilience even more critical.


Why capacity matters as much as capability


Having the right skills is only part of the equation. Trustees must also have sufficient time and capacity to fulfil their responsibilities effectively.


However, a meaningful capacity assessment must go further. It should also consider contingency capacity, including the ability to respond to:

  • market shocks or investment stress events
  • significant operational failures
  • cyber incidents or data breaches
  • unexpected trustee absences

Boards operating at full capacity under normal conditions may struggle to respond effectively in these scenarios. This creates a real risk to governance quality at precisely the moments when strong oversight is needed most.


Bringing skills and capacity together


Future-proofing requires an integrated view of skills and experience (what the board knows), and capacity and availability (what the board can realistically deliver). Combining these perspectives allows trustee boards to:

  • Identify whether gaps should be addressed through training, recruitment or structural change.
  • Reassess whether current board size and composition remain appropriate for effective governance.
  • Strengthen succession planning and resilience.
  • Ensure committees, delegations and governance structures are fit for purpose.

Taking action now


With so much change on the horizon, proactive action is essential. Trustee boards should not wait for weaknesses to become apparent under pressure. By reviewing board composition now, and making any necessary changes, schemes can ensure they are well positioned to meet future challenges and deliver strong outcomes for members.

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Enhancing administration reporting - insights and best practice


As master trust arrangements continue to evolve, the quality and clarity of administration reporting provided to trustee boards plays an increasingly critical role in supporting effective governance and member outcomes.


Following an informal comparison of administration reports across a range of master trusts, we are sharing our reflections on good practice (the standards TPR would generally expect to see in place), emerging best practice (examples of particularly effective or innovative approaches), and identifying areas where reporting can improve trustee oversight.


Below, we share some of our key observations and practical takeaways that may help schemes enhance and modernise the effectiveness of their reporting.


Start with the essentials


Keep it concise: Remove unnecessary branding, duplication, and low-value content that cause the reports to be lengthy. Trustees and administrators should regularly ask themselves what’s the purpose and value of the data on each page.


Lead with a dashboard: Clear, upfront summary of key risks, priorities, and performance, including comparisons with previous reporting. Clearly flag exceptions or deteriorating trends.


Administration performance


Monitoring administration performance should extend beyond reviewing service level agreements (SLAs). This is because performance issues can build up and processes can work inefficiently even whilst SLAs are met.


Good practice reporting also includes:

  • reporting on key performance indicators and service quality metrics
  • the age of the oldest outstanding activity for each administrative process (even where overall performance of the activity was within SLA)
  • the volume of pending or outstanding activity for each administrative process (broken down into workable and non-workable)
  • commentary on missed SLAs including explanation of cause, expectations about performance and when appropriate including a “road to green” (with owner, actions, timeline, impact)
  • quality assurance findings and progress against resulting actions

It is good practice for trustees to analyse the activity that is being conducted outside of SLA targets, even when the overall performance is within tolerance levels. This is where the trustees’ oversight role can really add value by providing challenge and considering any inefficiencies or necessary improvements. Where SLAs are consistently met, trustees may want to consider whether SLAs are set at appropriate levels and reflect the desired member experience.


It is best practice to report on both:

  • end-to-end processing times – reflecting the overall member journey; and
  • stopped clock processing times – reflecting internal operational performance to help identify areas for improvement

Integrating SLA performance reporting with complaints analysis, customer feedback, external reviews, and social media monitoring can provide a more rounded insight into the member experience and trend identification.


Member contact and digital platforms


To better understand the member experience, it is good practice to monitor metrics on all communication channels for example:

  • email volume received, including categories showing reasons for contact, response times and outstanding queries
  • call volumes, reasons for contact, calls answered, speed to answer, call duration and first-time contact resolution rates
  • Member satisfaction scores split by channel (web, calls, and email)
  • volumes of vulnerable members identified and any support provided.

It is best practice to also report on digital platform usage, including:

  • website visits
  • app downloads;
  • portal and app logins
  • online member journeys started and completed;
  • volume of online claims
  • beneficiary updates
  • system availability and service performance; and
  • any issues affecting the member experience such as outages or slow response times

Integrated monitoring


Each scheme will structure their reporting and oversight differently so some of the areas outlined below may be covered elsewhere in greater detail. However, including them within the board pack for whichever group oversees administration helps ensure administrative, financial compliance, and operational risks are considered in the round. Whether as a high-level summary or detailed update, this supports effective oversight and decision-making. It enables trustees to maintain comprehensive oversight across the full administration landscape and the formation of a holistic, transparent, and joined-up view of scheme administration performance and governance.


Financial processing:

  • Suspense account balances, including volumes and ageing.
  • Unit reconciliations and investment variances.

Compliance:

  • Incidents, compliance breaches and statutory disclosures (including confirmation that none have occurred in the reporting period).
  • Updates on any audit activity that has taken place in the reporting period or is upcoming in the next reporting period including details of actions arising.
  • Confirm whether statutory communications have been issued on time, together with related volumes.

Fraud:

  • Volumes, financial impact, any reimbursements or compensation paid, preventative measures and control improvements.

Resilience:

  • Third-party business continuity planning and testing outcomes and learnings.
  • Administration resourcing visibility and capacity risks.

Continuous improvement:

  • Updates on process improvements and administration projects.
  • Data scores including updates on any data improvement initiatives.

While there is no one-size-fits-all approach to administration reporting, the exercise highlighted a clear direction of travel: more focused, data-driven, and insight-led reporting that supports effective trustee decision-making and helps to identify emerging risks sooner. Trustees should report in a way that is proportionate to their scheme's size, complexity and risk profile, with reference to TPR’s Administration of a pension scheme guidance.

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Manage your cyber risk from emails


Email remains one of the primary methods of communication used in running pension schemes. However, it is also one of the most common routes exploited by cyber criminals.


We are aware of examples of personal email addresses being used for scheme-related correspondence and where a single email address is used by an individual acting as trustee across multiple schemes. While there may be legitimate reasons for these arrangements, trustees should consider whether the associated cyber and operational risks are being appropriately identified, assessed and managed.


Why it matters


Where controls around email use are insufficient there is an increased risk of:

  • unauthorised access to scheme information
  • phishing and business email compromise attacks
  • accidental disclosure of confidential information
  • difficulty maintaining appropriate records and audit trails
  • challenges in managing access when trustee appointments change
  • confusion regarding which scheme communications relate to where an individual acts across multiple schemes

Trustees should consider whether adequate safeguards are in place to maintain confidentiality, support effective record-keeping, and ensure a clear separation of communications and information between schemes.


Trustees may find it helpful to review their current arrangements and consider the following questions:

  • Do trustees use dedicated email accounts for trustee business?
  • If a personal account is used is this subject to the same security controls, monitoring arrangements or governance standards that are applied to organisational accounts?
  • Are email accounts protected by appropriate security controls, such as strong passwords and multi-factor authentication?
  • Is there a clear process for granting, reviewing, and removing access to trustee communications?
  • How are trustee communications and records retained and archived?
  • Are there controls to ensure information relating to different schemes is appropriately separated?
  • Have cyber risks associated with trustee communications been considered as part of the scheme's wider cyber security arrangements?
  • Do service providers and professional trustees follow consistent standards when communicating with schemes?

The answers to these questions will enable trustees to consider whether adequate safeguards are in place to maintain confidentiality, support effective record-keeping, and ensure a clear separation of communications and information between schemes.

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Trustee board and committee observations – good practice


Under our new ways of working, some of the master trust supervisors have been undertaking trustee board and committee observations. These provide a valuable opportunity to understand governance in practice, including board dynamics, the quality of challenge, the effectiveness of reporting and oversight, and how decisions are made in the interests of members. While every scheme’s governance arrangement is different, several themes emerged consistently as examples of good practice.


Committee summaries


Boards can strengthen their communication between committees and the full board by including concise committee summaries within board packs, and allowing committee chairs to highlight key discussions, decisions and actions. This helps ensure all trustees remain sighted on significant developments and emerging risks.


Self-assessment


We also observed boards setting aside time at the end of meetings to reflect on what worked well and what could be improved during the meeting. Regular self-assessment supports continuous improvement and helps boards refine their effectiveness over time.


Engaging chair


The role of the chair was particularly important. Effective chairs help set the tone and culture of the board, ensuring all voices are heard, challenge is constructive, discussions remain focused, and decisions are reached in a collaborative and well-informed manner.


Diversity


Effective boards recognise that good governance is about more than technical knowledge and understanding. While experience and expertise are fundamental, boards also benefit from a blend of skills, perspectives and personalities that enable trustees to provide robust challenge while maintaining constructive working relationships.


Secretariat support


A strong company secretariat function can also be critical to board effectiveness. An effective co-sec plays a central role in planning agendas, coordinating papers, supporting actions and governance processes, and ensuring meetings run smoothly. While often working behind the scenes, the quality of secretariat support can significantly influence the effectiveness of board discussions and decision-making.


Preparation time


A common theme was ensuring trustees have sufficient time to absorb board papers and debate complex issues. Some schemes support deeper discussion by holding dedicated sessions for significant strategic matters, reducing the risk that important topics receive insufficient scrutiny because of time pressures.


Audit trail


Boards should periodically review committee structures, delegated responsibilities, and succession arrangements. They should also consider whether discussions held in closed sessions or outside formal meetings are sufficiently documented to maintain a clear governance audit trail.


Member focus


Finally, the most effective boards consistently challenged themselves to focus on member outcomes. Asking “What is the benefit to members?” helps ensure decisions, strategic priorities and governance activities remain aligned with delivering good outcomes for members.


Following each observation, we provide feedback to the scheme. While these observations are not intended to be a formal board effectiveness review, they offer an opportunity to highlight examples of good practice and identify areas trustees may wish to reflect on further. By sharing these insights, we hope to support continuous improvement across the market and promote effective governance that delivers good outcomes for members.

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Inheritance tax reforms - further preparation guidance

HMRC has published a further technical note to support pension scheme administrators with their preparations on the Inheritance Tax (IHT) changes due to take effect from April 2027.


From 6 April 2027, most unused pension funds and death benefits under registered pension schemes will be included in the value of an individual’s estate when calculating inheritance tax (IHT), regardless of scheme discretion.


In our last bulletin we highlighted the important role pension scheme administrators are expected to play in supporting the new arrangements. This included providing information to support personal representatives, managing information-sharing requirements, and ensuring robust administrative processes are in place. The recent technical note provides further information that may help administrators, particularly on how the information sharing requirements will work.


Implications for DC master trusts


To ensure members can be adequately supported from April 2027, trustees should ensure their administrators are aware of this latest publication and are taking any necessary actions as part of their preparations.


This may include considering the impact and required changes on administrative processes, data requirements, controls and communications.


Trustees may also find the publication useful when discussing administrator readiness for the reforms.

Read the technical note

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New publication reveals how master trust default assets are invested


We have published our Master trust asset allocation 2026 report, providing new insight into investment allocations across default arrangements.


To support our ongoing monitoring and supervision of master trusts, asset allocation data was collected to better understand how master trusts invest default assets. The publication contributes to the evidence base on asset allocation, establishes a baseline for monitoring market trends, and provides greater transparency and visibility of master trust asset allocation in the market.


The analysis examines data from 25 master trusts as at 31 December 2025, covering £207.7 billion of assets and 74% of all master trust assets. Key findings include:

  • Public markets account for the majority of default assets, with equities and bonds making up 88% of default assets.
  • As members approach retirement, investment arrangements shift from equities to bonds, with equities falling from 77% at 30 years to retirement to 26% at retirement, while bonds rise from 13% to 56%.
  • Most master trusts have some exposure to private markets, but deeper allocations are less common, with around 60% of master trusts having some unlisted private market exposure, while around 20% have at least 5%.

The publication also includes a combined table bringing together data from FCA contract-based group personal pension providers with TPR's master trust data to provide wider workplace DC market context. Readers may also wish to refer to the FCA's Asset Allocation Survey for additional background on the contract-based pension market.


We are planning to continue our investment data collection exercise next year and will engage with schemes in due course. Building on the insights from this first exercise, future collections will continue to support TPR’s supervision activities, strengthen the evidence base on asset allocation, support the monitoring of market trends, and provide greater transparency and visibility of master trust asset allocation across the market.


Read the full Master trust asset allocation 2026 report for more information on asset allocation across the master trust market.

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Bank of England's Private Markets System-Wide Exploratory Scenario Exercise: Round 1 launch


In June 2026, the Bank of England launched Round 1 of the second System-Wide Exploratory Scenario (SWES), issuing a hypothetical stress scenario to selected participants across banks, insurers, pension funds, asset managers and alternative asset managers. The full SWES scenario has now been published.


The exercise focuses on the UK private markets ecosystem and aims to better understand how banks and non-bank financial institutions (NBFIs) would respond to a severe economic downturn. It will examine whether participants’ actions could amplify stress across the financial system or disrupt the provision of finance to the UK corporate sector.


The Bank of England expects to publish interim findings following the completion of Round 1 of the exercise, with the final report expected in the first half of 2027.


The exercise models a severe but plausible global macro-financial stress scenario over a five-year period. Participants are asked to assess the impact of the hypothetical stress scenario on their businesses/schemes and the actions they would take in response. The scenario assumes UK GDP falls by 4%, inflation peaks at 7%, the Bank Rate rises to 7% and global equity markets fall by more than 35%.


Implications for DC master trusts


Master trusts that have not been contacted by the Bank of England are not expected to take any action. However, trustees and providers may find the interim findings helpful when reviewing governance, risk management and private market allocations within default arrangements.


Further information can be found at: The Bank of England’s private markets system-wide exploratory scenario exercise.

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Too hot to grow


Extreme heat is no longer only an environmental challenge, it is becoming a substantial macroeconomic, fiscal, and investment risk, particularly for Europe. According to the report Too hot to grow: The economic costs of extreme heat by Allianz Research, heat stress is a structural economic challenge that can affect productivity, corporate profitability, infrastructure, public finances, and long-term investment returns. The impact compounds through lower investment, deteriorating public finances and growing social vulnerabilities.


Heat can affect economies through several channels. The economic transmission of heat stress is non-linear, with a critical threshold around 30°C beyond which productivity losses intensify sharply, while energy demand rises as cooling requirements increase. Over time, these pressures can reduce economic output, weaken investment, increase inflation, and place additional strain on government budgets. For long-term investors such as pension schemes, these impacts may influence asset values, funding levels, and sponsor covenant strength.


One of the report's most important findings is that heat damages investment more than consumption. The mechanism is straightforward:

  1. Heat reduces productivity
  2. Profitability falls
  3. Expected returns on capital decline
  4. Investment is postponed or cancelled
  5. Future productive capacity shrinks

Therefore, heat becomes a drag not only on current GDP but also on long-term growth potential.


Why is this relevant for pension schemes?


Pension schemes are exposed to climate-related risks through their investments, sponsoring employers and long-term liabilities. Extreme heat has the potential to affect a wide range of asset classes, including equities, infrastructure, property, and private markets, particularly where assets are located in regions with high heat exposure.


Potential considerations for trustees

  • Economic growth risk: sustained heat stress may reduce GDP growth and corporate earnings and it should be viewed as a recurring economic shock rather than a rare climate event.
  • Investment risk: physical assets and infrastructure may face operational disruption and higher adaptation costs.
  • Inflation risk: increased energy demand and supply constraints could contribute to higher prices.
  • Fiscal pressures: governments may face rising expenditure and lower tax revenues, with implications for public finances and bond markets.

Key opportunities and responses

  • Assess climate resilience within investment portfolios through stress scenario analysis.
  • Consider how managers evaluate physical climate risks and adaptation measures.
  • Identify sectors and companies benefiting from climate adaptation solutions, such as cooling technologies and resilient infrastructure.
  • Review climate-related risks as part of broader stewardship and risk-management frameworks.

As the frequency and severity of extreme heat events increase, trustees should assess whether existing governance, investment, and risk management frameworks sufficiently incorporate the potential economic impacts of extreme heat and their implications for member outcomes.

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Individual member transfers out – TPR engagement


Transfers between pension arrangements are becoming an increasingly important area of focus across the pensions industry. As member engagement with pensions savings continues to increase, transfer activity is expected to grow, driven in part by the greater use of pension tracing and the anticipated impact of pensions dashboards.


At the same time, transfer-out processes can be a significant source of member complaints, particularly where members experience delays, poor communication, or uncertainty regarding the status of their request.


Over recent weeks, we have been engaging with a number of authorised master trusts to understand the systems and processes used to process individual member requests to transfer-out of schemes.


We would like to thank all schemes that have taken the time to respond to our request for information and to share their experiences, data and insights. The quality and openness of the responses received have been extremely valuable and demonstrate the sector's ongoing commitment to delivering good outcomes for savers.


The purpose of this engagement is to help us with our supervision duties in understanding whether the systems and processes used in running master trusts are sufficient to ensure that they are run effectively. The information will also inform our understanding of current practices across the master trust market, identify examples of good practice and emerging risk, and explore any common challenges that may be affecting the member experience. Ultimately, the information will inform our wider supervisory and policy approach and conversations with the FCA and DWP on this topic.


What are we looking at?


The engagement focuses on areas relating to systems and processes such as:

  • transfer-out processes and operational arrangements
  • transfer timescales, service standards and reporting
  • member communications and support
  • common causes of delays and complaints
  • destination trends and emerging risks
  • approaches to due diligence and transfer checks
  • opportunities to improve member journeys and industry consistency

We are also seeking to better understand wider industry initiatives intended to improve transfer processes and member outcomes.


Future engagement and next steps


We selected a sample of schemes to provide a range of perspectives from across the market.


As our work progresses, we expect the findings to inform future discussions with industry and may contribute to wider communications on transfer-out good practice and regulatory expectations.


We are currently reviewing the information received and identifying common themes, challenges, and examples of effective practice. We will consider how the insights can support our supervisory approach and whether there are opportunities to share learning more broadly with the sector. We anticipate providing further updates in due course and, where appropriate, sharing observations that may help schemes enhance transfer processes and improve outcomes for members.

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Members with guaranteed benefits transferring to master trusts - case study


One of the key challenges for some single employer defined contribution schemes transferring to a master trust has been the position of members who are invested in a with-profits policy which entitles them to bonuses and guarantees under the terms of the policy. On a transfer out, typically, the with-profits policies are surrendered, which means that guarantees and bonuses will be lost going forward. One of the schemes TPR has oversight of has recently been exploring this challenge.


One of the objectives of the project was to ensure that members who are invested in a with-profits policy would be no worse off as a result of a transfer to a Master Trust, but without cashing in and topping up members’ accounts in the transferring scheme. In order to achieve this, agreement has been reached to novate the with-profits policy from the trustee of the single employer DC scheme to the trustee of the master trust. As a result, transferring members will not see any change to their existing rights under the with-profits policy, including to future guarantees and bonuses paid under the terms of that policy.


Another complication that can affect schemes looking to transfer to a master trust is the potential for some members to lose their entitlement to protected tax-free cash. This can happen if some of the transferring members are already members of the receiving master trust in respect of other periods of employment. One of the schemes TPR has oversight of has also resolved this by transferring affected members to a second master trust instead, operated by the same provider and identical in all material respects save for the method of tax relief applied. This enables the master trust permitted membership condition to be complied with and the entitlement to protected tax-free cash to be preserved.

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