What the FCA’s Pensions Regulatory Priorities report means for pensions providers

What happened?

The FCA has published its Pensions Regulatory Priorities report, the third in its 2026 series following Insurance and Consumer Investments, with six further sector reports due across the year.

The report sets out the FCA’s supervision priorities, how it intends to enable innovation, and a ‘what we expect firms to do’ section that firms can use for gap analyses and monitoring plans.

Speaking at the TISA Inclusive Investing Conference, the FCA’s Lucy Castledine highlighted that nearly 15 million people are not saving enough for retirement.

Why does it matter?

The report continues work on value for money, with proposals to tackle poorly performing workplace schemes to be followed by a wider review of value for money in pensions and savings products that allow investment in unit-linked funds.

Firms may be required to transfer customers to better solutions if value for money is not delivered, which carries real operational and commercial impact for advisers and providers.

The FCA is also moving to a ‘show me, don’t tell me’ supervisory approach, with the Enforcement Watch report showing 23 enforcement operations opened since 3 June 2025, six relating to potential Consumer Duty breaches.

Who is affected?

Pensions providers and advisers, particularly those operating workplace schemes or products allowing investment in unit-linked funds, sit at the centre of the value-for-money work.

Firms supporting ‘gone-away’ customers or those with vulnerabilities face particular attention, since the FCA is concerned these groups risk poor retirement outcomes due to older or less innovative products.

Key risks

• Workplace schemes or unit-linked products that do not deliver adequate value for money.
• Poor product governance, complex charging structures and lack of transparency for consumers.
• Weak oversight of appointed representatives.
• Consumers of older or less innovative products facing reduced choice, flexibility and higher costs.

Actions to take

1. Use the ‘what we expect firms to do’ section as a gap analysis and monitoring tool.
2. Prepare for potential customer transfers if value for money is not being delivered.
3. Review product governance, charging structures and transparency, particularly for older or legacy products.
4. Strengthen oversight of appointed representatives and evidence of good consumer outcomes.

Wider implications

The Regulatory Initiatives Grid links this report to a wider Pension Reform Steering Committee Group agenda, bringing together the FCA, the Department for Work and Pensions, HM Treasury and The Pensions Regulator.

That coordination, alongside measures in the Pension Schemes Bill and initiatives such as pensions dashboards, suggests the direction of travel on value for money and consumer support is unlikely to slow.

Recommendations

Test control frameworks against the FCA’s expectations now, rather than waiting for the next sector report or supervisory request.

Focus particularly on evidencing good outcomes with reliable data, since the Consumer Duty’s emphasis on value for money, communication quality and consumer decision-making runs through this report.