Third instance of undelivered statutory communications identified and reported

The Pensions Regulator (TPR) has published a regulatory intervention report into NOW: Pensions Trust, one of the UK's largest authorised master trusts, setting out three separate failures to deliver statutory communications to members and potential members¹. In April 2022, as part of compiling its response to information request notices issued during a TPR investigation, NOW: Pensions Limited (NPL) identified a third instance of failure to deliver statutory communications, specifying that a further 30,919 communications had not been sent¹. TPR received a breach of law report one day after the discovery, following a decision by NOW: Pensions Trustee Limited (NPTL) earlier the same day, but the matter was not reported as a significant event¹.

The report describes two earlier incidents. In April 2019, NPL discovered a "no reply" mailbox had received bounce-back notifications from emails it had attempted to send to members dating back to February 2018¹. An internal review between September 2019 and October 2020 found that emails had failed to be delivered because of invalid or missing email addresses, affecting more than 35,000 communications, of which around 9,500 were mandatory¹. In February 2021, following that review, a decision was made not to report the incident to TPR as either a significant event or a breach of law¹.

In May 2021, NPL became aware of further communication failures in relation to missing email addresses¹. By July 2021 the investigation showed a further 29,000 statutory communications had not been sent dating back to 2018, and 86 employers had been affected¹. NPL concluded by 22 July 2021 that this second set of failures was a breach of law but decided to conduct an internal investigation rather than report it at that time; NPTL was made aware in July 2021 and also did not report it¹. A breach of law report was made in October 2021, which TPR says was outside the timeframe considered reasonable, and no significant event report was submitted¹.

TPR opened an investigation in February 2022¹. Warning notices were issued to NPL and NPTL in August 2023 seeking penalties of £50,000 each¹. The case was referred to the Determinations Panel in August 2024, and in November 2024 the panel issued a Determination Notice imposing a £50,000 penalty on each entity, the statutory maximum for this type of breach¹. Both have paid in full¹. TPR says this is the first time it has taken enforcement action against an authorised master trust for statutory failures to report¹.

Why it matters for households

The failures concerned communications that scheme rules and pensions law required to be sent to members and potential members, including statutory communications¹. The Determinations Panel noted that the communication failures caused both financial and non-financial harm to members and potential members, and that they took away members' opportunities to make decisions about their pensions¹. The affected group is people whose email addresses were missing or invalid in the scheme's records, with failures dating back to February 2018¹. The penalties were imposed on NPL and NPTL, not on members, and both were paid in full¹. The report was published on 18 July 2025¹.

What happens next

No further steps are set out in the report. TPR states that the case sets a clear expectation that master trusts must comply with reporting obligations or risk financial penalties, and that schemes should be preparing for their connect-by date for connecting to pensions dashboards¹. Members wanting an overview of how dashboards will work can read our guide to pensions dashboards, and general information on workplace schemes is in our pensions section.