The Pensions Regulator delivers ‘underarm bowl’ to administration with helpful data quality guidance

23 February 2026

The Pensions Regulator’s new guidance on scheme member data quality provides a simple and practical framework for assessing and improving the quality of member data.

Data as a strategic asset

Central to the guidance is the notion that schemes need to treat their member data as a strategic asset.

As we discussed in our recent blog post, Pensions dashboards: The gateway to digital pensions administration, scheme administration has a longstanding profile problem. Up to now, administrators have rarely been seen as a strategic partner at the trustee table, where areas such as investment generally garner more interest.

However, developments such as the pensions dashboards and this latest regulatory guidance push member data – and administration more broadly – up the agenda of every scheme.

Data quality and scheme end games

The rationale for this regulatory focus is that the better your data is, the more effective your scheme will be in servicing its members during day-to-day administration. Crucially, a saver’s user experience of the pensions dashboards will also hinge significantly on the quality of data held by the scheme. And good quality data is incredibly important to the end-game strategy too.

Trustees preparing for a buy-out soon learn how important data quality is when negotiating with insurers on risk transfer pricing. Schemes need to give insurers complete clarity on the risk they’re buying into, and data is central to that.

In recent years, scheme run-on has emerged as a formalised end-game strategy. Schemes that decide to run on will progressively give members more digital options. A manual process is much more forgiving of the data used, as administrators can review and correct details as they go along. For an online transaction carried out by a member in real time, on the other hand, all the data that might conceivably be needed has to be 100% correct.

Data is the base layer, sitting under the platforms, tools and processes of a digital journey. Only with good quality data can schemes even consider innovations such as online retirement.

So whether a scheme’s end game is to buy-out or run on, member data has to be seen as a strategic asset.

What does quality data look like?

TPR’s guidance builds on the industry’s experience of preparing data for the pensions dashboards.

The centrepiece of the guidance is what TPR calls the six data quality dimensions:

• Accuracy
• Completeness – no missing data
• Consistency – alignment of data across all instances
• Timeliness – up-to-date information whenever it’s needed
• Uniqueness – i.e. no duplication
• Validity – correctly formatted data.

Schemes need the correct data in place at the right time. In a digital world, these six dimensions have never been more important, as we discussed in our recent blog post on pensions dashboards and digital administration.

Data improvement plans

If the six data quality dimensions are central to TPR’s guidance, then data improvement plans sit alongside them. With a robust governance element, data improvement plans are designed to give schemes “a structured framework for planning, documenting and delivering data improvement activity”, as PASA (Pensions Administration Standards Association), which has produced a template data improvement plan, noted.

This builds on substantial work in this area. There are already four regulatory data reports – one for common data, one for scheme-data, and then two pertaining to the Pensions Dashboards Programme.

In addition, as an established part of First Actuarial’s scheme administration onboarding process, we produce an implementation report assessing data quality and itemising any data issues uncovered during the transition period.

We’ve also been working on a standard data improvement plan, which we are now revisiting in light of TPR’s guidance and PASA’s recommended template. We’ll be inserting this into our administration processes, to be produced immediately after onboarding.

We particularly welcome the flexibility of the guidance for scheme-specific needs. We have to remember that not every scheme was within the scope of the Pensions Dashboards Programme, for example. Data improvement management must reflect the reality of every scheme.

Data improvement in practice

The guidance outlines an overarching data quality process:

• Identify
• Review
• Measure
• Improve.

That aligns with the spirit of our existing approach to data quality, which in practice, can take a number of forms, including actions arising from:

• Formal data management processes
• Common data reporting
• Scheme-specific reporting
• Information tracing such as address checks and mortality screening
• Data cleansing integral to specific transactions.

The guidance states that data quality needs to be reviewed at least twice a year. This goes over and above industry practice right now, and makes complete sense once everyone recognises data as the strategic asset that it is.

The guidance TPR provides on data scoring deserves a special mention. Although common data scoring is both established and consistent, the same cannot be said for scheme-specific data scoring. More consistency in this area will help TPR to assess scheme performance, and drive significant improvements in scheme-specific data. Guidance on data quality would have been incomplete without this valuable element.

Batting TPR’s underarm bowl

As scheme administrators, we’re the day-to-day custodians of data quality. TPR’s recognition of data as a strategic asset could not be more important to administrators like us who have been striving to get a place at the table for some time. TPR has bowled us an underarm bowl and we’re going to give it a good whack.

This guidance is only the start of a transformative data journey that TPR will be taking every scheme on. Administration’s focus on data quality is officially vindicated and the rest is down to us.