Is providing information enough, or should trustees actively engage with members?
This simple question opens up fundamental issues about what pensions are really for.
What the rules require
Trust-based schemes must follow the Disclosure Regulations 2013, which specify what information to provide and when – but they focus on disclosure, not understanding. The Pension Regulator’s Code of Practice says trustees should provide “clear and relevant information,” but the emphasis is typically on compliance, not comprehension.
By contrast, contract-based schemes are held to the high standards of Consumer Duty. But why should member experience differ based on scheme type?
How we’re seeing this play out in the real world
Progress has stalled
Remember auto-enrolment? It was supposed to be just phase 1. Phase 2 would focus on engagement, and phase 3 on auto-escalation. Years later, we haven’t made enough progress. Without these later phases, many members won’t (and don’t) save enough for retirement.
Our industry prioritises accuracy over helpfulness
Too many schemes focus on what’s legally (or actuarially) accurate without challenging those factors with what will best help members. They view risk through a disclosure lens (“Did we tell them?”) rather than an outcomes lens (“Did they understand and act appropriately?”).
There’s a DB-DC disconnect
Most regulations originate from the DB world, focused on ‘avoiding harm’. But in the DC world, where outcomes depend disproportionately on member actions, is avoiding harm enough? Without engagement, we face a future where 65-year-olds discover: “I can’t retire now”.
But there are signs of change
New initiatives suggest a shift in thinking. The DWP’s ‘targeted support’ requirements aim to provide personalised guidance at key moments. They’re also planning to require DC schemes to provide default decumulation solutions for members who don’t make active decisions – tacit admission that information alone isn’t working.
How we can do better
Learn from the Consumer Duty
One of the major changes Consumer Duty introduced on the FCA side of the industry, was to put responsibility on providers to ensure members understand. It puts the focus on outcomes, not process – not just “Did we send it?” but “Did they get it?”
Use engagement as a tool to improve other things
Good engagement improves other metrics too. Clear communication can reduce complaints, decrease call volumes, and improve scheme efficiency. It’s not just a nice-to-have, it can make a meaningful difference to other areas of scheme governance.
Rethink your success metrics
Let’s stop only counting clicks and start measuring decisions. Are members making choices that lead to better retirement outcomes? That’s the real measure of engagement success.
Work with human nature
Auto-enrolment succeeded by acknowledging how people actually behave. We need the same approach with engagement – meeting members where they are, using communication strategies that reflect real-world decision-making.
Think bigger than compliance
If pensions exist to provide retirement security, then meaningful engagement isn’t optional – it’s essential. My experience in our industry is that when you ask people about their ambitions, people almost universally talk about good outcomes for members. But it’s all too easy in the day-to-day to fall back on our rules and processes rather than challenge ourselves to look from the member’s perspective.
As regulations shift toward outcomes, forward-thinking schemes can lead rather than follow – not just ticking boxes but redefining what good looks like.
What do you think? How can we transform engagement from a compliance exercise to something that helps people retire better?
