Main Concerns

• Terminology and Focus – The consistent use of “savers” instead of “members” reflects a DC-centric bias. AMNT urges TPR to adopt inclusive terminology applicable to both DB and DC schemes.
• Purpose and Clarity – References to “long-term economic resilience” risk conflating TPR’s regulatory role with wider economic policy aims. The enforcement strategy must focus squarely on member outcomes.
• Transparency and Accountability – The draft lacks sufficient detail on decision-making, prioritisation, escalation processes and coordination between TPR and other regulators (e.g., FCA, PRA, ICO, TPO).
• Proportionality – Smaller schemes and volunteer trustees could struggle to cope with the same administrative and regulatory burdens as large, well funded schemes. Enforcement must be proportionate and supported by accessible guidance.
• Trust Law Context – The strategy underplays the legal and fiduciary framework governing trustees. Enforcement must recognise the distinction between technical non-compliance and genuine misconduct.
• Early Intervention Risks – Trustees may hesitate to self-report if early engagement automatically leads to enforcement. The strategy should assure trustees that early disclosure will be treated constructively.

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Recommendations

• Clarify Enforcement Framework: Publish clear criteria, thresholds, and case studies. These should explain how enforcement decisions are made and prioritised.
• Differentiate DB and DC Priorities: Address enforcement areas specific to DB schemes, such as covenant monitoring, buy-out risks and TPA oversight.
• Define “Prudential” Approach: Ensure the term is applied appropriately within occupational pensions, avoiding duplication of trustee obligations.
• Enhance Coordination: Establish clear protocols and memoranda of understanding with other regulators to avoid duplication or conflict.
• Embed Proportionality: Provide guidance and improvement plans for smaller schemes before formal enforcement.
• Introduce Safeguards: Include transparent escalation, appeal and review processes. Clarify how self-reporting will be handled.
• Measure Success: Use outcomes-based metrics such as reduced breaches, faster case resolution, greater voluntary engagement and improved trustee confidence
• Communications: Clear communication and stakeholder engagement plans should accompany the final enforcement strategy.

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