IGG responds to DWP Consultation on Trustees and Governance

At Independent Governance Group (IGG), we believe the Government should refine and strengthen the existing trusteeship framework rather than fundamentally reshape a system that is already delivering for members.

In our response to the Department for Work and Pensions consultation, Trust-based pension schemes: Trustees and Governance, building a stronger future, we welcomed the ambition to raise standards across the industry. However, we emphasised that reforms should build on what already works, preserving the proportionality, flexibility and diversity of governance models that underpin the current system.

Our response focuses on strengthening capability and accountability without introducing unnecessary complexity. In particular, we have called for:

• Refinement, not redesign, of a framework that already provides clear fiduciary accountability, proportionate oversight and a widely understood governance baseline.
• Recognition of the role of professional trustees and Professional Corporate Sole Trustee (PCST) models, particularly in complex funding, endgame strategy and consolidation scenarios where clarity and continuity improve outcomes.
• Support for integrated service models, which have developed in response to market demand and have broadened access to high-quality governance and specialist expertise for smaller schemes, ensuring more members benefit from strong governance.
• A rigorous conflict management process that ensures transparency and accountability, rather than restricting trustee firms from offering complementary services that improve member outcomes. Conflicts exist across all trust-based structures, and fiduciary duty remains a powerful legal safeguard.
• Mandatory accreditation and proportionate firm-level oversight for professional trustees, with a tiered structure that supports progression and helps sustain a diverse pipeline of trustee talent.
• A continued emphasis on collective board competence, recognising the increasing importance of skills in areas such as data governance, artificial intelligence, cyber resilience and digital administration alongside sound judgement and collaborative capability.
• Stronger governance expectations around member engagement and communications, ensuring member perspectives are systematically captured regardless of governance model.

Our perspective – Louise Davey, Trustee Director and Head of Policy and External Affairs at IGG, said:

“Many elements of the current trusteeship framework are operating effectively across trust-based schemes. It’s important that we see evolution, not revolution. Clear legal accountability, proportionate oversight and flexible governance models mean the system largely works well. Reforms should strengthen these foundations, not dismantle a framework that is delivering improved governance and member security.

“Professional trusteeship, including Professional Corporate Sole Trustee models, has strengthened governance capability, improved decision-making and provided continuity at critical stages such as funding negotiations, endgame planning and consolidation. These structures operate within the same fiduciary framework as any other, and that duty remains a powerful safeguard for members. Acting as the ‘voice of the member’ is not solely the preserve of lay trustees; acting in members’ interests is the duty of any trustee, and that includes effective communication and engagement. That’s why our guiding principle is No Member Left Behind™.

“As schemes grow in scale and complexity, and the demands on trustees increase, the focus should be on higher, clearer standards, including mandatory professional accreditation and proportionate firm-level oversight, alongside robust conflict management. Conflicts are – and always have been – inherent in all trust-based structures; what matters is how they are governed.

“The opportunity is to raise standards in a way that remains proportionate, outcomes-focused and grounded in the practical realities of modern scheme governance.”

We set out our full analysis and recommendations in our consultation submission.

Read our full response here.