Pension schemes and their administrators are facing a convergence of pressures that make the state of their data more consequential than ever. Members expect clear, digital communication. Trustees must demonstrate robust governance and accurate benefit calculations. Regulators are demanding better data, stronger controls, and greater transparency. And underpinning all of it is a complex – often fragmented – mix of historical records, legacy systems, and partial digitisation.
The Pensions Regulator (TPR) has been unambiguous: trustees must treat member data as their most important “strategic asset”[1]. With the final pensions dashboards connection deadline of 31 October 2026 now less than a year away, schemes that have not addressed their data foundations risk regulatory enforcement, operational disruption, and poorer outcomes for members.
The data challenge pension schemes face
Most pension arrangements have grown organically over decades, shaped by scheme rule changes, provider transitions, mergers and acquisitions, and successive administration platforms. The result is that member data is typically scattered across different systems and time periods – and in many cases, across different physical formats as well.
TPR’s own research found that one in four pension schemes still hold some non-digitised records[1]. That means boxes of paper files, microfiche, and older scanned images that cannot be easily searched, reported on, or integrated with modern administration systems. Even straightforward tasks – verifying a member’s service history, tracing contributions, or responding to a benefit query – become unnecessarily time-consuming and error-prone when records exist in these formats.
The problem compounds when schemes attempt more complex work. GMP equalisation projects, past transfer reviews, and benefit rectification exercises all depend on complete, accurate historical data. Where that data is locked in legacy formats or scattered across multiple repositories, progress stalls. GMP equalisation in particular is consistently cited as one of the key factors slowing the path to buyout, with missing service data, legacy administration records, and inconsistent benefit specifications forcing manual intervention and repeated review[2].
Pensions dashboards: The regulatory deadline driving action
The pensions dashboards programme has transformed data quality from a governance aspiration into a regulatory imperative. Under the Pensions Dashboards Regulations 2022, all pension providers and schemes in scope must connect to the dashboards ecosystem by 31 October 2026. As of December 2025, over 700 providers and schemes had completed connection, representing more than 60 million workplace and personal pension records – approximately three-quarters of the total in scope[3].
But connection is only part of the story. TPR has made clear that the success of dashboards depends entirely on the quality of the data behind them. TPR’s November 2025 market oversight report revealed that while most schemes have made progress on cleansing personal data, value data – the information used to calculate benefits – is often overlooked. Improvement plans are frequently informal or fragmented, and trustee engagement varies widely, with some schemes placing near-complete reliance on their administrators[1].
The regulator is now scrutinising the data preparations of the UK’s largest schemes and expanding its engagement throughout 2026. Schemes unable to demonstrate compliance with TPR’s expectations may face formal intervention, including improvement notices[1].
For smaller and medium-sized schemes with connection deadlines falling in 2026, the volume of work required means the effective deadline for data preparation is much earlier than October. TPR’s guidance, consolidated and updated in November 2025, sets out expectations across six core data dimensions: Accuracy, completeness, consistency, timeliness, uniqueness, and validity[4].
AI and digital services: Why clean data is the prerequisite
Members are becoming increasingly comfortable with digital channels in every aspect of their lives, and they expect pension information to be accurate, available, and easy to understand. Artificial intelligence has a genuine role to play here – in explaining options, modelling retirement outcomes, and personalising communications – but only if the underlying member data is complete and reliable.
As TPR’s Interim Director of Policy and Public Affairs put it at a recent industry conference: If the data going into the system is not up to scratch, you are automating rubbish[5]. This observation applies equally to AI-driven analytics, automated member communications, and the dashboards themselves.
TPR has published a data strategy that includes establishing an AI advisory council to oversee the ethical use of AI technologies across the pensions industry[6]. As analytics and AI become more common, questions around data lineage, fairness, and accuracy will only intensify. Schemes that invest in their data foundations now will be best positioned to adopt these technologies safely and effectively.
Cybersecurity: Protecting data during digitisation and migration
Pension records contain some of the most sensitive personal and financial data held by any organisation. This makes pension schemes attractive targets for cybercriminals – and any data migration, system change, or digitisation project represents a moment of heightened risk.
The scale of the threat is significant. The UK government’s 2025 Cyber Security Breaches Survey found that over 40% of UK businesses experienced a cyber breach or attack in the past year[7]. For pension schemes, the consequences can be severe. The 2023 Capita breach – in which an unauthorised actor accessed systems containing data for over 300 pension schemes and 6.6 million individuals – resulted in a £14 million ICO fine and ongoing High Court proceedings[8].
TPR’s General Code now sets explicit expectations for cyber resilience, requiring that pension schemes maintain effective governance and internal controls to reduce cyber risk[9]. Trustees must ensure that any digitisation or migration work incorporates strong access controls, encryption, and monitoring throughout the data lifecycle. This is not merely good practice – it is a regulatory expectation, and the ICO has made clear it will take enforcement action where organisations fail to implement appropriate technical and organisational safeguards.
Making sense of historical pension records
Addressing the legacy data challenge is the single most impactful step most schemes can take towards better governance, smoother projects, and regulatory compliance. Schemes that have embraced data readiness are discovering that the benefits extend well beyond dashboards compliance. As the Pensions Dashboards Programme has noted, clean, structured, and accessible data transforms operations – a member query can be answered with a click rather than a paper chase, and trustees can run real-time analytics rather than relying on assumptions[10].
Effective historical records management means scanning paper and microfiche files at scale, capturing key data points such as service periods, salary history, benefit options, and member correspondence, then linking those documents and data to current administration systems. This enriched history can then be used to resolve discrepancies, fill gaps in member records, and support complex projects like GMP equalisation and benefit rectification with confidence.
For schemes approaching buyout, the quality of historical data directly affects transaction timelines and costs. Where GMP equalisation and underlying data cannot be resolved at scale, progress slows regardless of insurer appetite or market conditions[2].
Building a data foundation for 2026 and beyond
Schemes that want to be ready for the dashboards deadline – and the broader regulatory and operational demands that follow – should focus on four priorities.
First, conduct a thorough inventory of where member data and documents are held, including off-site archives, legacy administration platforms, and any records held by former service providers. Understanding the full scope of the challenge is the essential starting point.
Second, develop a structured plan for digitising and organising historical records so they can support day-to-day administration, strategic projects, and analytics. This means not just scanning documents but indexing them intelligently and extracting key data to populate administration systems.
Third, ensure that any data migrations or consolidations are carried out with strong governance, comprehensive testing, and appropriate cybersecurity safeguards. The risks associated with poorly managed data transitions – from regulatory penalties to member harm – are too significant to leave to chance.
Fourth, embed ongoing data quality management into scheme governance, so that issues are identified and addressed early rather than allowed to accumulate. TPR’s revised guidance makes clear that trustees are ultimately accountable for data quality, even where operational tasks are delegated to administrators[1].
How Dajon helps pension schemes take control of their data
Dajon Data Management works with pension schemes and administrators to address the practical challenges of legacy data at scale. Our services span the full lifecycle of pension records management, from bulk scanning of member files and scheme records with intelligent indexing, through to capturing key data from historical documents to support projects like GMP equalisation and improve ongoing accuracy.
We support secure data migration between administration systems, ensuring that records are transferred with robust controls and proper governance. And we help schemes design data management approaches that meet TPR’s evolving expectations – building the kind of sustainable data capability that supports not just dashboards compliance, but better member experiences, smoother projects, and clearer visibility of risk.
The industry faces what TPR has described as a “data debt” – the accumulated consequence of historical underinvestment in data management. By investing in data foundations now, pension schemes can begin to repay that debt and enter the next phase of regulatory and technological change with confidence.
- Trustees urged to get dashboards-ready by treating member data as a strategic asset The Pensions Regulator[↩][↩][↩][↩][↩]
- Why GMP equalisation and data challenges are delaying buyouts Heywood[↩][↩]
- Progress update report Pensions Dashboards Programme[↩]
- PASA publishes new Data Quality Guidance and Data Improvement Plan Template PASA[↩]
- Time for Some Spring Cleaning? Ombudsman’s Determination Shows Need to Press on With GMP Equalisation Pensions and Benefits Blog[↩]
- The Pensions Brief: April 2025 Mayer Brown[↩]
- WTW forecasts a £70bn UK pension risk transfer market in 2026 WTW[↩]
- Capita Cyber Security Breach – £14 Million Fine Issued Mayer Brown[↩]
- Is your pension scheme cyber risk ready? Mercer[↩]
- Getting data-ready for dashboards: benefits for savers and schemes Pensions Dashboards Programme[↩]