Last Updated February 2026
As pension risk transfer activity continues at pace, professional trustees are under growing pressure to demonstrate not just sound decision-making, but clear, defensible governance behind every strategic choice.
With The Pensions Regulator signalling its intention to extend oversight to professional trustee firms, scrutiny is shifting decisively towards how decisions are made, evidenced and documented. That focus is expected to centre on governance and decision making, particularly where outcomes materially affect scheme members.
PRT decisions sit squarely in that category. Whether closing to future accrual, entering a longevity swap, or pursuing a buy-in or buy-out, trustees should expect to show that process, evidence and transparency were integral to the decision, not applied retrospectively. In a market where timelines are tightening and complexity is increasing, governance discipline is no longer a background consideration. It is central to trustee accountability.
Beyond making good decisions (in the interest of scheme members) TPR will expect trustees to demonstrate that PRT decisions are built on reliable, objective and up-to-date information.
Mitigating and hedging risks that threaten the security of members’ benefits are in keeping with a trustees’ fiduciary duties. It is also in keeping with these duties that trustees ensure that each PRT transaction mitigate the risks and secure the benefits they were intended for. A big part to doing that is to show clear, documented evidence of data quality, validated benefit calculations (high level or detailed benefit audit), scheme benefit summary and transparent member communication. Demonstrating each of these areas with clarity and confidence is becoming a clear expectation for trustees when scrutiny is increasing and accountability is front and centre.
Greater examination from the regulator may prompt schemes to reflect more critically on where their advice is coming from and whether there is sufficient separation between those delivering recommendations and those validating them.
These governance expectations are emerging against a backdrop of sustained transaction volumes, compressed deal timelines and increasing competition across the PRT market.
Trustees don’t need to have all the answers themselves, though they do need to be confident in the integrity of the information they’re relying on.
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Every scheme is different, but there are common governance questions that should be considered by trustees:
With tighter deadlines and resource limitations, many trustees face increasing pressure to maintain high standards. So, how can technology help ease these pressures while supporting strong governance?
Whether that’s through automating data preparation, streamlining benefit validation or simplifying communications, tech-led solutions are enabling trustees to manage the demands of the risk transfer process and better evidence their decision-making process more efficiently. This will support better outcomes, even when resources are stretched.
Technology is playing an increasingly important role in helping trustees demonstrate best practice throughout the pension risk transfer process. From validating scheme data to auditing benefit calculations with greater speed, accuracy and evidence, tech-led solutions are helping trustees demonstrate good governance more efficiently and with greater confidence. With clearer insights, faster preparation and improved transparency, trustees are better equipped to move at pace and meet the expectations of advisers, insurers and regulators alike.
We’ve also recently discussed AI and it’s role in driving forward solutions that enable PRT transactions to move forward faster and more efficiently.
As PRT transaction volumes continue to rise, trustees face a dual challenge. They must move at pace to engage with insurers while also meeting rising expectations around governance, evidence and accountability.
Being able to clearly demonstrate how decisions were informed, validated and delivered is fast becoming a marker of strong trusteeship. It is no longer enough to reach the right outcome. Trustees must be able to show how they got there, why the approach was appropriate and how member interests were protected throughout.
Those who invest early in robust processes, reliable data and clear evidence trails will be better positioned to respond to regulatory scrutiny, engage confidently with advisers and insurers and deliver PRT transactions that stand up to challenge. In today’s market, good governance is not just a safeguard. It is a strategic advantage.