This reinforces a central point: the industry has moved quickly into surplus, but it is moving much more deliberately in deciding what to do with it.
TPR flags that new legislation on surplus release is now in place, with regulations to follow and further regulator views and guidance expected ahead of implementation. That sequencing is important: the law may open the door, but trustees will still need defensible decisions, robust governance and a clear articulation of fairness.
And while improved funding changes the landscape, it does not eliminate risk, it reshapes it. TPR continues to stress that trustees must understand risks to both investment strategy and employer covenant, particularly given economic and geopolitical uncertainty. The podcast discussion echoed this: funding risk hasn’t disappeared; it remains a factor that can derail strategy and influence whether surplus can be released safely. What has changed is the set of risks rising up the agenda for schemes expecting to exist for longer: cyber risk, operational resilience, and long-term uncertainties that are harder to hedge neatly.
That is why I believe working in partnership is key in this new era. For schemes that plan to run on and potentially release surplus, the next phase will demand judgement, deep expertise and repeatable decision-making frameworks.
One thing is clear, standing still is no longer an option and those decisions that were once theoretical are now distinctly real.
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