HL Pensions Law Digest 14 April 2025

Welcome to our latest update, in which we cover: 

• Pensions Regulator (TPR): using AI to fight pension scams 
  • TPR outlines its latest steps to combat pension scams and encourages continued reporting to Action Fraud. 
• TPR: small schemes and climate risk 
  • TPR believes that small defined contribution (DC) schemes should consider quitting the market if they cannot appropriately manage climate risk. 
• Pension dashboards: videos from TPR 
  • TPR has released some short films to encourage dashboard readiness and to raise awareness of dashboards more widely. 
• PASA guidance on data readiness for buy-ins and buy-outs 
  • Updated guidance from PASA on preparing data before buy-ins or buy-outs. 

Pensions Regulator: using AI to fight pension scams 

The Pensions Regulator (TPR) has issued a press release announcing that it and the Pension Scams Action Group (PSAG) have created a new tool to detect scam websites using artificial intelligence (AI). 

Key points are: 

• To date, PSAG has reviewed 830 websites, taken down 29 high-risk sites and made 94 referrals to partner agencies. 
• Later this year, a new Fraud and Cyber Crime Reporting and Analytics Service will replace Action Fraud. In the meantime trustees should continue to report to Action Fraud. 
• Despite guidance on reporting to Action Fraud, surveys by TPR show that only 11% of schemes correctly said that scams should be reported to Action Fraud. 
• On 25 March, PSAG ran a webinar on fighting fraud, together with the City of London Police.The webinar is available to watch on TPR’s website. 

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Pensions Regulator: small schemes and climate risk 

The Pensions Regulator (TPR) has stated that small defined contribution (DC) schemes which do not appropriately protect savers’ retirements from climate risk should consider quitting the market. According to TPR’s data, only 17% of DC schemes dedicate time or resources to climate risk. In contrast, 100% of master trusts and 92% of larger DC schemes do so.

Alongside this statement, TPR has published its Climate adaptation report 2025, TPR’s contribution to the national assessment of the UK’s resilience to climate change. The report outlines the findings of various surveys and earlier reports, and explains the existing legislation, codes of practice and guidance on addressing climate risks and opportunities. 

TPR plans to continue to: 

• Educate and support trustees, while questioning decisions when appropriate; 
• Use its enforcement powers against trustees who do not comply with statutory requirements; 
• Encourage trustees to improve their capabilities in relation to climate change and sustainability and to go beyond minimum compliance; and 
• Work with government and other parties to improve management of climate and ESG risks. 

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Pensions dashboards: videos from TPR 

The Pensions Regulator (TPR) has issued some short videos of interviews with members of the public about their current pension awareness and how helpful they would find it to have all their pension information in one place on a dashboard. The series of videos is part of TPR’s campaign to encourage the pensions industry to become dashboard ready. The films are being shared on social media and with industry stakeholders.

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PASA guidance: data readiness for buy-ins and buy-outs 

The Pensions Administration Standards Association (PASA) has issued updated guidance (first released in February 2023) on data readiness for buy-ins and buy-outs. While aimed at preparing data for buy-in / buy-out, the principles could also be relevant to schemes aiming at alternative end-game solutions. Appendices to the guidance list relevant data items for: all members; members still in employment with the sponsoring employer; deferred members; pensioners; and dependants, and categorise each data item as being of high, medium or low importance. 

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Authored by the Pensions team.