1.  Amongst the most serious failings of Opra, The Pensions Regulator's predecessor, was its tendency to treat all cases the same. This approach prevented it from directing resources at the areas that needed most attention and it became heavily burdened by the quantity of data it collected. The Pensions Regulator (TPR) has put in place processes for determining the schemes which present the greatest risk to members and for collecting data according to its risk assessments.

2.  TPR has information on 99% of final salary schemes by membership, but on only 32% of money purchase schemes. It has made good progress in regulating final salary schemes, but is only now implementing an approach to money purchase schemes. TPR expected to have largely completed its database of all pension schemes by March 2008. It should use it to identify those money purchase schemes presenting the highest risk and direct its regulatory effort towards them.

3.  Fewer than a third of schemes have a conflict of interests register and only two-thirds offer formal structured governance training. Although TPR has defined what constitutes good governance, standards remain low in many pension schemes, particularly among money purchase schemes and smaller schemes. TPR should raise awareness within these schemes of the standards that it expects and the assistance available, and it should target those schemes that fall short of the required standards.

4.  Only 15% of all trustees are registered on TPR's trustee web-based training toolkit and the majority do not complete all the modules. TPR needs to increase take-up of its toolkit and guidance materials for trustees. It should use its database of schemes and of registered users of the toolkit to identify those trustees who have not yet completed the toolkit. TPR should then communicate with these schemes to encourage take up of the toolkit.

5.  TPR has set itself a goal of year on year improvement in governance standards, but has not been clear about the extent of desired annual improvements or its ultimate goal for governance standards. TPR should set specific targets for the yearly improvements in overall governance standards that it seeks to achieve and for the minimum standard it aims to achieve in the longer term.

6.  TPR has been given greater enforcement powers than Opra, but so far has made little use of them. Where schemes are not governed well, TPR must intervene to ensure that members' benefits are protected, and that the scheme is meeting its statutory objectives. Whilst TPR should only use such powers when there is good reason to do so, it must avoid appearing reluctant to use them.

7.  In order that its regulatory expectations are clear, TPR needs to be transparent in its decision making. Initially, TPR did not publish its determinations, but in September 2007 agreed to publish them in future, except in special cases. It also undertook to publish all past determinations except where there was a good reason not to do so, and should do this without delay in order to bring clarity and transparency to its past decisions.

8.  Lack of understanding amongst members is a key risk to money purchase schemes but TPR has done little to generate improvements. No explicit promises are made to members about the level of their final pension, and they bear all the risk that funds accumulated on their behalf may not provide a reasonable pension. TPR should review with the Financial Services Authority the adequacy of the information provided to members about their likely pension and work with the Financial Services Authority to fill in any gaps identified.