Pension schemes are carrying a burden that rarely appears on a balance sheet but affects every member interaction: data debt. This is the accumulation of outdated, incomplete or non-digitised records that slow down administration and create operational risk. Recent findings from The Pensions Regulator show that many schemes still rely on legacy data structures, and some continue to hold information that is not yet digitised. When this happens, trustees struggle to meet regulatory expectations and face added pressure during dashboard preparation.
Data debt develops when schemes postpone data maintenance or rely on older records that have not been checked for accuracy. Over time, gaps widen. Without a structured approach to validation, trustees may believe their data is stronger than it is. These gaps in many schemes data may result in issues for the dashboards launch or delay its roll out.
MM supports schemes that want to move away from reactive data work and toward a model where data is reliable and accessible. Managing overseas proof of life, validating member status and confirming key details are all easier when data can be checked quickly and consistently. Schemes that invest in improving their records often discover issues that would not have surfaced through normal administration. These include incorrect addresses, incomplete status information and records that have not been updated following changes in personal circumstances.
Reducing data debt is not a single project. It requires steady, ongoing effort with annual reviews. Trustees who take action early benefit from smoother operations, fewer manual interventions and improved confidence when reporting to regulators. Clearer data allows schemes to respond faster to member enquiries and to support administrators who need to work efficiently.
As the regulator increases its focus on data quality, this topic is moving to the top of the agenda. Schemes that treat data as a strategic asset will be better placed to manage future requirements. MM can help strengthen member records, reduce uncertainty and support a more resilient data environment.
The Pensions Regulator. (2025) Scheme member data quality. Available at: https://www.thepensionsregulator.gov.uk/en/trustees/contributions-data-and-transfers/scheme-member-…
Pensions Age. (2025) ‘TPR urges trustees to treat member data as “strategic asset” as review reveals dashboards risks’, Pensions Age, 18 November. Available at: https://www.pensionsage.com/pa/TPR-urges-trustees-to-treat-member-data-as-strategic-asset-as-review…