The UK Opened a Consultation on Pension Trustees' Fiduciary Duty Guidance on 5 November, Closing 27 January 2027: What Fund Managers Pitching UK Pensions Should Check

On 5 November 2026 the UK Department for Work and Pensions (DWP) opened a consultation on draft guidance that explains how pension trustees should apply their fiduciary and related duties when making investment decisions. The consultation closes at 11:59pm on 27 January 2027. The DWP stressed that the guidance does not change the law, create new fiduciary duties or alter trustees' legal responsibilities. For fund managers who raise money from UK pensions, the draft is worth reading because it describes the process trustees say they will follow when they weigh an investment, which is the process your pitch has to fit.

What was published

The draft was developed by a technical working group and an advisory group chaired by Robin Knowles. It brings existing legal principles and practical considerations together in one reference document. It covers how trustees can identify and assess financially material factors, how they can consider risks and opportunities over different time horizons, and how they can take account of sustainability, systemic and economy-wide factors. It also looks at how those considerations may inform investment decisions, stewardship and collaborative activity, and at the link between investment outcomes and members' future costs and living circumstances. The draft includes illustrative examples, and it emphasises evidence, appropriate advice, proportionality and trustee judgement. The consultation asks whether the draft gives a balanced and practical explanation of the existing framework and whether any part needs clarification, amendment, more evidence or further examples. The government will use the responses to decide whether the guidance gives trustees enough clarity before it is finalised.

Dates to note

The consultation opened on 5 November 2026 and closes at 11:59pm on 27 January 2027. The consultation page lists two documents, the consultation document and the draft guidance itself, and says responses can be sent online or by email to the DWP. If you intend to comment, plan to submit before the deadline. The government and the technical working group said the draft has the potential to be a useful reference point for trustees, advisers and others involved in investment decisions, but that any final guidance needs further evidence, expertise and practical experience from across the pensions sector. The draft is not final guidance, and we have not seen a date for publication of the final version.

Why this matters for fund managers

Fund managers are not the audience for the guidance, and nothing in it regulates you directly. It matters because UK trustees are among the largest sources of institutional capital, and a document that describes how they should reason about investments will shape the questions they ask. We have been tracking this market closely. We reported that UK pension providers held £22.1 billion in private markets under the Mansion House Accord, and that two UK workplace pensions have now opened venture programs through managers. Trustees read guidance alongside advice from their consultants, so we would expect the language of financial materiality, time horizons and evidence to turn up in manager questionnaires and in the presentations trustees ask managers to give. As more of that capital moves toward private assets, the standard for how trustees document their reasoning becomes part of the sales process. On the fund-regulation side, we also covered the FCA's overhaul of the UK AIFM regime, which closed for comment on 22 October 2026.

What to check

This section is our suggestion, not guidance from the DWP. First, read the draft yourself and note which parts touch your strategy, in particular the sections on financially material factors, time horizons and systemic risks. Second, check whether your pitch materials identify the factors you consider financially material to your strategy and show the evidence behind them, because the draft stresses evidence and proportionality. Third, make sure you can show how you would help a trustee record its reasoning, for example by providing clear reporting on the risks and opportunities you monitor over different periods. Fourth, review how you describe stewardship and collaborative activity, since the draft covers both. Fifth, if you hold views on whether the draft is clear enough for private-market investing, consider responding to the consultation or asking a trade body to carry your comments. Sixth, expect trustees and their advisers to ask more detailed questions in their due diligence questionnaires as the guidance settles.

What we do not know

The consultation does not set out new duties, and we have not seen the final text. It is also not yet clear how trustees of different sizes will apply the guidance, or whether changes after the consultation will alter the examples. We therefore treat the draft as a signal of direction rather than a rule to comply with. For a view of the investors affected, see our list of UK pension funds, and for where trustee demand is heading, you can see which UK pensions are building private markets programs.

This is not legal advice. Consult a qualified lawyer on how the draft guidance and your own obligations apply to you.

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