The Pensions Regulator published guidance titled Use of artificial intelligence (AI) in pension schemes on 29 October 2026, together with press release PN26-19. The guidance sits within the regulator's scheme management detailed guidance for governing bodies and is addressed to trustees and scheme managers.
The guidance states that the use of AI does not change a trustee's existing duties and responsibilities, and that it is not intended to establish new and separate regulatory requirements. It applies the obligations trustees already carry: to act in line with the trust deed and rules, in the best interests of members, in accordance with legislation, and impartially, prudently, responsibly and honestly, alongside trustee knowledge and understanding requirements and the requirements on governance, systems and processes. External instruments named in the guidance are the Equality Act 2010, the EU AI Act and UK data protection law, with guidance issued by the Information Commissioner's Office and the Financial Conduct Authority.
Trustees are responsible for all scheme processes, whether outsourced or internal, so boards relying on administrators, investment managers or advisers that run AI tools must secure information, assurance and contractual rights and review them regularly. Exit provisions carry weight, including how scheme data is returned when a provider changes. Where trustees act as controllers, they are responsible for complying with data protection law and for demonstrating the compliance of AI systems, with automated decision making singled out where significant decisions are made with no meaningful human involvement.
The seven principles are: start with the problem, not the technology; human responsibility remains central; governance is ongoing, not one-off; plan for disruption; good AI starts with good data; transparency and explainability underpin trust; and support fair and accessible outcomes. On security, the guidance says AI can increase risk by enabling more convincing scams, including phishing or social engineering, and directs trustees to the regulator's cyber security principles. It also cautions against staff use of unapproved public AI tools.
Licentium advises pension scheme trustees, administrators and technology suppliers on the governance and contractual arrangements that AI deployment demands. Work we undertake includes mapping where AI sits in a scheme's processes, drafting provider oversight and exit terms, aligning automated decision making with data protection duties, and preparing trustee boards to question suppliers about model behaviour.
Source: The Pensions Regulator, Use of artificial intelligence (AI) in pension schemes, 29 October 2026