Pension trustees could face significant challenges implementing The Pensions Regulator's (TPR) new artificial intelligence (AI) guidance, despite widespread support for its principles-based approach, according to industry experts.
Responding to the guidance, published yesterday, pensions professionals welcomed the regulator's efforts to encourage responsible AI adoption but warned that trustee boards would need time to understand the recommendations and assess their existing governance arrangements.
The guidance outlines seven key principles for trustees and scheme managers, covering human oversight, data quality, transparency, risk management, and accountability.
TPR has stressed that the guidance does not create new regulatory requirements but instead explains how existing trustee duties and governance expectations apply to AI.
However, Aon partner, Paul McGlone, warned that the breadth of the guidance could prove challenging for schemes.
McGlone noted that the speed at which AI was being adopted, and at which TPR had responded, was noticeably faster than previous technological challenges, such as cyber risk, which had taken many schemes years to properly consider.
He welcomed the regulator's recognition that AI should not be treated as a standalone technology project but instead integrated into wider scheme operations and governance.
"The extent of it will be daunting for many and, in our experience, no scheme is currently able to say that they do everything that it suggests," he added.
"Schemes will need to devote time to properly considering the guidance, digesting it fully, and thinking about how to apply it in a proportionate way."
Sackers partner, Oliver Topping, also welcomed the guidance: "AI is a powerful tool which can help improve and deliver any number of efficiencies but, as TPR clearly acknowledges, this comes hand-in-hand with certain risks, two obvious candidates being hallucinations and cyber threats.
"There are also hidden dangers for members in using freely available AI to help plan for their retirement."
Topping emphasised that trustees and scheme managers were not expected to become AI experts, especially given how many scheme functions are delegated to third parties.
However, he suggested schemes may need to develop AI policies depending on how trustees and their advisers used the technology.
"In what is an ever evolving and rapidly growing area, the guidance provides a sensible and pragmatic framework," he continued.
"Trustees and scheme managers should take the time to discuss the guidance with relevant advisers, assess existing and possible future AI use, before deciding on what steps might be needed next."
Meanwhile, Association of Consulting Actuaries (ACA) AI Steering Group chair, Kiran Mandalia, welcomed the regulator's decision to adopt a flexible approach, recognising that schemes would have different requirements and levels of exposure to AI.
"TPR has rightly taken a principles-based approach here: one size doesn't fit all," Mandalia said.
"AI can feel daunting for some trustees, and a clear set of questions to work through gives them a practical place to start."
Society of Pension Professionals (SPP) council member, Matthew Giles, also welcomed the guidance, describing it as a timely contribution to the industry's understanding of AI.
He argued that it recognised the opportunities to improve scheme services, decision-making and member outcomes, while reinforcing the importance of governance, human oversight and accountability.
"The guidance provides a helpful starting point for trustees and their advisers to ask the right questions, understand the risks and embrace innovation responsibly," he added.
"It is encouraging to see a proportionate approach that builds on existing duties rather than creating unnecessary new requirements, helping the pensions sector navigate this rapidly evolving landscape with confidence."














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