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As the UK’s pension sector continues to consolidate and progress, the role of professional trustees has never been more pivotal. The announcement by The Pensions Regulator (TPR) last week (April 2025), confirming its plans to roll out a formal oversight framework for professional trustee firms, marks a significant step in how scheme governance will be monitored—and ultimately, how saver outcomes will be protected.
At Flint Hyde, we see this change not just as a regulatory milestone, but as a leadership and talent opportunity for firms looking to future-proof their governance models.
Professional Trustees: From Administrators to Strategic Actors
The growth of the professional trustee industry has been one of the most marked changes in the UK pensions market in recent years. According to TPR and various industry surveys, around 50% of schemes now use a professional or sole trustee, with sole trustee appointments growing rapidly. These firms now oversee more than £1 trillion in assets, with over £75 billion managed under sole trustee arrangements alone. That’s a considerable influence on the direction, integrity, and effectiveness of UK pension schemes—whether Defined Benefit (DB), Defined Contribution (DC), or hybrid.
But as their influence has grown, so too has the complexity of their roles. Professional trustees are increasingly responsible for day-to-day operational governance, steering through complex regulatory compliance, balancing employer interests with member protections, integrating ESG principles, and managing cyber risk and conflict of interest. They are no longer simply administrators. They are decision-makers, risk managers, and in many cases, the strategic heart of a pension scheme.
Inside the Regulator’s Shift: From Scheme-Level to Market-Level Oversight
Recognising the growing complexity of the sector, TPR is adopting a prudential-style regulatory approach—one that looks not only at individual schemes, but at the systemic risks posed by the business models that govern them. Over the past six months, the regulator has engaged directly with 11 of the UK’s largest professional trustee firms. These conversations explored ownership structures, diversity and inclusion, remuneration and profitability, conflicts of interest, and how decisions are made at an operational level.
The findings revealed a diverse and highly competitive market, but also flagged potential vulnerabilities. These include the risk of excessive delegation without proper oversight, tensions between cost efficiency and quality of governance, and the blurred lines created when firms offer bundled services such as advisory, secretariat, or administration. The use of in-house advisers in particular presents a challenge, with concerns raised around independence, indemnity, and accountability.
Industry Reaction: Welcoming Oversight, With a Focus on Ethics
The industry response to TPR’s announcement has been largely positive—and notably swift. Andrew Bradshaw, CEO of the Independent Governance Group, emphasised the importance of oversight for firms that now govern in excess of £1 trillion in pension assets. “It is right that we are held to a high bar,” he said, “and keep striving to raise the standards of trusteeship and governance.”
Rachel Croft, Chair of the Association of Professional Pension Trustees (APPT), welcomed the regulator’s focus and committed to continued engagement, while Dalriada Trustees’ Adrian Kennett echoed the need for high standards and greater alignment across the sector. Others, like Ian Bell of RSM UK, suggested the framework must also include clear ethical guidelines—similar to those in audit and accountancy professions—to ensure trust, transparency, and independence remain front and centre.
TPR’s own commitment to working collaboratively with the industry is encouraging. The regulator has expressed a clear desire to identify both risks and examples of best practice, using regulatory dialogue and targeted engagement as tools to lift standards across the market.
What This Means for Talent: Raising the Bar on Governance Leadership
The elevation of trusteeship to a role of strategic significance inevitably places greater demands on those delivering it. There is now an increasing need for professional trustees to demonstrate not just pensions expertise, but robust governance capability, commercial judgement, and ethical leadership.
As TPR tightens its oversight, trustee firms will need to evolve too—building teams with more diverse skills, strengthening internal controls, and investing in long-term talent. At Flint Hyde, we are already supporting trustee firms and pension funds to identify, assess, and appoint governance leaders who bring both technical competence and integrity to the role. The trustees of the future will need to work around regulation, ESG, cyber resilience, and scheme innovation, often simultaneously. The bar is rising, and the organisations that invest in talent today will be those that succeed.
What Comes Next?
TPR’s framework for professional trustee oversight will begin rolling out in summer 2025, starting with targeted expert-to-expert engagement and eventually expanding to cover the wider market. The regulator has committed to taking a proportionate, risk-based approach—gathering data, refining expectations, and stepping in where necessary. Where material risks are found, TPR has indicated it will not hesitate to act.
But this isn’t just about compliance. This is about partnership. The regulator has made clear it wants to build a constructive dialogue with the market, raising standards without stifling innovation. As one industry leader put it, professional trustees should be “at the forefront” of governance, risk management and member outcomes.
Governance Is a People Issue:
As this movement in oversight unfolds, we are reminded of one simple truth: good governance is powered by good people. Oversight, frameworks, and regulation are essential—but it’s the people in the room who make decisions, uphold standards, and deliver outcomes.
For trustee firms, scheme sponsors, and pension providers, this is a moment to invest in leadership—to build teams who understand governance, embrace responsibility, and are ready for the regulatory scrutiny to come.
At Flint Hyde, we see this as a watershed moment in UK pensions. If you’re thinking about how your governance model needs to evolve—or the talent required to support that evolution—we’d love to talk.
Research: https://www.thepensionsregulator.gov.uk/en/document-library/research-and-analysis/market-oversight-professional-trusteeship