The Pensions Regulator (TPR) has been urged to provide greater clarity on how it will be applied in practice and how smaller schemes will be treated under the new approach, despite broad support for its proposed new enforcement strategy.

The comments were made in response to follow the TPR's recentconsultation on its draft enforcement strategy, which aims to make enforcement smarter, more strategic, and more impactful.

In its consultation response, the Society of Pension Professionals (SPP) said it backed the “broad thrust” of TPR’s proposals but cautioned that some elements could lead to “unintended outcomes” without further clarification.

The SPP agreed that assessing enforcement priorities based on impact, scale, and complexity was a reasonable framework, but warned this could be “misunderstood” to suggest that smaller schemes would be less likely to face enforcement action.

The group also highlighted the risk that limited regulatory resources might lead to a focus on high-profile cases involving larger schemes.

“There may be a temptation to concentrate on egregious corporate activity at larger or less well-funded schemes,” the SPP said.

“However, it remains important that TPR continues to challenge poor behaviours even in well-funded schemes and avoids any perception of different standards.”

It added that the regulator must remember that “low dependency is not no dependency” and should remain alert to risks across all scheme types.

The SPP also used its response to flag emerging uncertainty around the new surplus flexibilities introduced under the Pension Schemes Act 2021.

Several members, it said, had raised concerns that trustee decisions to release surplus, or advice given to support such decisions, could inadvertently fall foul of the act’s criminal offences.

Subsequently, the society called on TPR to review its enforcement and criminal offences policies “in light of the new surplus rules” to avoid discouraging appropriate use of surpluses.

Meanwhile, the Association of Professional Pension Trustees (APPT) also supported TPR’s overall direction but described the strategy as “very high level”, warning that its effectiveness would depend on how it is implemented in detailed policies to follow.

The APPT said the strategy’s focus on prioritising enforcement for “maximum impact” made sense, but stressed the importance of ensuring sufficient resources and training to deliver on this ambition.

It warned that additional staff recruitment and specialist training would likely be necessary to embed the changes successfully.

While welcoming the emphasis on outcomes and proportionality, the APPT expressed concern that cases involving smaller schemes or lower aggregate impact could fall down the priority list.

“Whilst understandable given finite resources, this could create a perception that TPR has less interest in smaller schemes or lower-benefit members,” the group stated, adding that clearer communication on how “other responses” might be used in such cases would help build confidence.

The APPT also urged greater transparency around TPR’s internal decision-making processes, noting that “decisions appear to rest with internal panels” and are influenced by available resources.

“More transparency about how consistent criteria are applied would help build trust without exposing the process to gaming,” it added.

Meanwhile, both organisations agreed that the strategy aligned with TPR’s shift toward a more risk-based, preventive regulatory model, but called for clearer accountability measures and defined success indicators.

The APPT suggested that public reporting against key metrics, such as reductions in fraud or improved saver confidence, would help demonstrate the real-world impact of enforcement actions.

The concerns raised echoed the response of the Pensions Administration Standards Association (PASA), which suggested that a clearer distinction between issues best addressed through guidance and those requiring enforcement would strengthen TPR's proposed approach.

The consultation closes on 11 November, and TPR is expected to finalise the strategy alongside a refreshed suite of enforcement policies in 2026.

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