The UK government has opened a consultation on draft guidance for occupational pension trustees, seeking to clarify how existing fiduciary and investment duties apply to long-term decision-making.
The Department for Work and Pensions published the draft on 5 November after a technical working group chaired by Sir Robin Knowles examined areas in which trustees and advisers have sought greater certainty. The consultation follows a commitment made during the passage of the Pension Schemes Act 2026.
The guidance does not purport to change trustees’ legal duties. It is intended to explain the existing framework and support the exercise of trustee judgment, including the treatment of financially material factors and the relationship between investment strategy and members’ long-term interests. The government says trustees’ primary obligation to act in members’ best interests remains intact.
The draft also preserves the distinction between legal duty and policy preference. Trustees would remain responsible for applying the law to their own scheme, taking advice where necessary and documenting the reasoning behind investment decisions. The working group presents the guidance as practical assistance rather than a safe harbour or replacement for case-specific analysis.
The consultation runs for 12 weeks, from 5 November 2026 to 28 January 2027. Responses will inform whether the text should be revised before final guidance is issued.
Official consultation and draft guidance
