In the UK, The Pensions Regulator (TPR) in September 2026 unveiled a new outcomes-focused enforcement approach that prioritizes early intervention and data-driven risk detection over rigid compliance checks, aiming to prevent harm to pension savers before it occurs.
Under the framework, TPR will evaluate potential enforcement cases based on three factors: impact, scale, and complexity. High-impact or high-scale cases will typically take priority even when straightforward, while low-impact, low-scale cases may be handled through guidance or communications rather than formal enforcement, unless they signal a broader pattern of risk.
TPR chief executive Nausicaa Delfas said the shift moves the regulator away from “tick-box” oversight toward a system-wide view centered on ensuring savers achieve a sustainable retirement income. The strategy rests on five objectives, including targeting the highest-impact risks, responding decisively to non-compliance and economic crime, and improving transparency through greater use of data.
Particular attention will be paid to vulnerable members, including lower-income workers at greater risk of financial hardship in retirement. Serious economic crime cases—covering fraud, money laundering, and organized or cross-border financial crime—will be escalated in partnership with law enforcement.
Delfas urged industry stakeholders to engage early when issues arise, noting that enforcement action should come as “no surprise.” Persistent non-compliance or serious harm could still trigger penalties, trustee removal, or prosecution. With TPR now signaling clearer expectations and faster intervention, schemes and employers should expect closer scrutiny of how proactively they manage emerging risks.
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