Status when last reviewed, 28 July 2026: the Government response to this consultation has not been published. Everything below describes a proposal and the industry's reaction to it. None of it is settled policy, and nothing here should be read as a prediction of what the Government will decide.
What Was Consulted On
The Department for Work and Pensions consulted on "Trust-based pension schemes: Trustees and governance, building a stronger future". The consultation opened on 15 December 2025 and closed on 5 March 2026.
Its central proposal was to put professional trustee standards on a statutory basis. At present the standards that professional trustees are held to are industry-run. The Association of Professional Pension Trustees and the Pensions Management Institute each operate an accreditation regime, both built on the standards published in 2019 by the Professional Trustee Standards Working Group, and both are voluntary. A person can act as a professional pension trustee in the UK today without being accredited by anyone.
The consultation also explored whether accreditation should be made mandatory, and for whom.
Why This Came Up
Trusteeship in the UK has changed shape considerably over the past decade. Professional and sole trustee appointments have grown, particularly in defined contribution consolidation and in schemes moving towards buy-out, and a much larger share of scheme assets now sits under boards where at least one seat is held professionally.
Alongside that, the governance expectations placed on trustees have risen. The Pensions Regulator's General Code of Practice, which came into force in March 2024, consolidated ten of TPR's previous codes into a single set of governance modules and set out its expectations for an effective system of governance. The statutory requirement to have and maintain trustee knowledge and understanding has been in place since the Pensions Act 2004.
Against that background, the policy question is a reasonable one. If professional trusteeship is now a material part of how UK pension schemes are run, should the standards for it sit in statute rather than in a voluntary industry code?
How the Industry Responded
The published responses split along a fairly clear line.
On professional trustees, support was broad. Respondents including PMI, the Association of British Insurers, Law Debenture and Broadstone were supportive of raising and formalising standards for trustees acting in a professional capacity. That is not surprising. The firms and bodies most active in professional trusteeship already operate to the accreditation standards, and a statutory floor would mainly affect those who do not.
On extending mandatory accreditation to all trustees, responses were noticeably cooler. The recurring concern was the effect on the lay trustee pipeline. Member-nominated and employer-nominated trustees are, by design, people who came to the board from another job. Requiring every one of them to pass exams and clear accreditation checks would narrow the pool of people willing and able to serve, at a time when many schemes already find member-nominated vacancies hard to fill. Several respondents argued that the existing statutory knowledge duty, supported by The Pensions Regulator's free Trustee Toolkit, already addresses lay trustee competence without that side effect.
Those are the arguments as made in the responses. Which of them the Government finds persuasive is not something anyone outside the Department knows.
What Is Still Undecided
Everything that matters, in short. As at the date this post was last reviewed, the Government had not published its response, and so the following are all open:
- Whether professional trustee standards will be placed on a statutory footing at all
- If they are, whether accreditation becomes mandatory for professional trustees
- Whether any mandatory requirement would extend beyond professional trustees to lay trustees
- What transitional arrangements would apply to trustees already in office
- Which body or bodies would operate any statutory scheme, and how existing APPT and PMI accreditation would be recognised
- The timetable for any of it
We will update this post when the response is published. Until then, treat any confident account of the outcome, from us or anyone else, with suspicion.
What This Means for the APT Today
Nothing has changed. The requirements that exist now are the requirements that existed before the consultation opened.
If you are pursuing professional trustee accreditation through APPT or PMI, the route is unchanged: complete The Pensions Regulator's Trustee Toolkit, pass CPT Unit 1 (the Award in Pension Trusteeship), pass CPT Unit 2, clear the fit and proper checks, and then maintain 25 hours of CPD a year of which at least 15 are structured, with a fresh DBS check every three years. Our guide to becoming an accredited professional pension trustee sets that out in full.
If you are a lay or member-nominated trustee, no qualification is required of you today, and the statutory duty that does apply is the trustee knowledge and understanding duty under the Pensions Act 2004. We have covered what that duty actually requires separately.
What the consultation does change is the calculation for people who were putting the exam off. Three public sittings a year means the APT takes months to acquire, and PMI lists 18 March, 15 July and 17 November for 2026. If a statutory requirement did eventually arrive with a transitional deadline, holding the qualification already would be a more comfortable position than starting from scratch alongside everyone else. That is a scheduling argument rather than a prediction, and it is the only one we think is safe to make.
A Note on the Related Legal Framework
Some of the ground the consultation covers is already examinable in the APT syllabus, which is worth knowing if you are studying while following the policy debate.
The distinction between disqualification and prohibition is one example. Under the Pensions Act 1995, certain events disqualify a person from acting as a trustee automatically and by operation of law, with no order required. Under the Pensions Act 2004, The Pensions Regulator can separately make a prohibition order against a person it does not consider fit and proper, and can make a suspension order as an interim measure. These are different mechanisms with different triggers, and the exam tests the difference. They sit in the appointment, composition and removal of trustees.
The statutory "fit and proper persons" test is another. It exists in UK pensions law today, but it applies specifically to master trusts under their authorisation regime rather than to trustees generally. The APPT and PMI fit and proper checks are a separate, voluntary, industry standard. Conflating the two is a common error and a fair target for an exam question.
Sources and Standing
This post describes the consultation document, its closing date and the published responses of named organisations. It does not attribute any view to the Department for Work and Pensions beyond what was consulted on, and it does not state or imply that accreditation is or will become mandatory.
Trustee Prep is an independent practice platform and is not affiliated with or endorsed by the Pensions Management Institute, the Association of Professional Pension Trustees or The Pensions Regulator. Nothing here is legal advice.
If you are getting ahead of the exam rather than the policy, practice on The Trust and Its Creation is free with no card required.
Start practising APT questions free.