From Reactive to Proactive: The Pensions Ombudsman's Corporate Strategy

19 August 2025. Published by Damien O'Malley, Associate and Shauna Giddens, Senior Associate

On 30 July The Pensions Ombudsman (TPO) published its three-year strategy and corporate plan which proposes to address the significant rise in pension related complaints and deliver a more responsive, accessible and effective service.

TPO's latest figures highlight the scale of the challenge it faces. In 2024/25, it closed 9,435 complaints: a marked increase of 42% from the previous year where it closed 6,634 complaints. Incoming complaints also increased substantially by 39%, greatly exceeding TPO's own estimation of 15%. Whilst this rise in complaints may reflect heightened customer awareness and improved access to the service, it also places significant strain on TPO's capacity.

The three-year strategy

The strategy sets out TPO's three-year roadmap to tackle rising demand. To do this, it sets out two key goals: 

  1. Improve the quality and efficiency of service. 
  2. Lead the way in driving improvements across the industry, particularly in relation to pensions administration and complaint handling. 

The first of these goals is designed to build upon the momentum created by the implementation of TPO's Operating Model Review (OMR), which introduced new methods of processing cases such as lead-case handling, quicker informal resolutions, and a more flexible approach to how determinations are made. TPO intends to implement additional methods of improving efficiency such as the use of AI for administrative matters (as opposed to decision making tasks which will remain human led).

The second goal is aimed at reducing the number of complaints TPO receives in the first place through collaboration with schemes, providers and regulators to prevent the escalation of complaints. This includes the publication of clearer guidance, the improvement of schemes' internal dispute resolution processes and raising public awareness of customer rights. TPO aims to be more than a service provider but a leader in the sector. It plans to publish sector insights, share lessons learned from the cases it receives and develop relationships with stakeholders across the pensions sector from regulators to policy makers.

These goals are clearly designed not just to improve how TPO operates, but also to reshape how the wider pensions industry operates. TPO suggests that achievement of these goals will result in the following outcomes: 

  • Improved pension scheme administration;
  • Greater recognition of TPO as a key part of the pensions supervisory sector;
  • Improved complaint handling across the industry; and
  • Increased public awareness about pension complaints.

The Corporate Plan

The 2025/26 Corporate Plan sets out the groundwork for TPO's broader three-year strategy. Their key priorities for 2025/26 include:

  • Sustaining recent gains in case handling, targeting a 4% year-on-year increase in closures;
  • Managing demand through better public information, sector engagement, and signposting;
  • Improving access for users by making the complaints process clearer and more inclusive;
  • Developing staff capability, with a focus on training, decision-making consistency, and wellbeing; and
  • Modernising systems and governance, including exploring longer-term funding models.

The Plan acknowledges that efficiency in itself will not be enough. Even if case closures rise each year, the unprecedented level of growing demand means that TPO will need the assistance of the wider industry to resolve issues at an earlier stage to reduce the number of referred complaints.

TPO also notes the potential for complaints with – (1) the Pensions Schemes Bill and its new initiatives including default decumulation options, (2) the Pensions Dashboard with the expectation that data issues are discovered before the 2026 go-live date and once the dashboard is live consumers identifying issues with their pensions, (3) the consolidation of smaller schemes and (4) complaints continuing around scams, pension transfers and auto-enrolment.

What comes next?

As consumer awareness of pensions rights heighten, TPO's role becomes increasingly critical. The Corporate Plan and Strategy indicate that, rather than taking a reactive stance, TPO is considering the long-term. 

The success of TPO's strategy will ultimately hinge on how well the sector engages with the TPO to collaboratively meet the rising challenge of surging complaint levels. Ultimately, TPO isn't just changing how it works, it is trying to change the wider sector in which it works and hopes that this will result in fewer disputes, better outcomes, and an overall more confident sector. Time will tell whether TPO can meet these lofty goals.

 

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