AI in UK Pensions & Retirement Income
At the moment someone first draws on a pension, its two regulators have reached for different protections against AI. Which one applies depends on whether the pot sits in a contract or a trust.
Why this briefing
The FCA's targeted support regime went live on 6 April 2026. It lets firms make suggestions designed for groups of consumers with common characteristics, outside the COBS 9/9A suitability standards. When it confirmed the regime, the FCA recorded respondents' view that there is "an inherent tension between artificial intelligence (AI), which enables a high degree of personalisation, and the targeted support regime" — and answered that it remains "comfortable that the outcomes-focused nature of targeted support enables it to remain fit for purpose as technology develops".
Five months later The Pensions Regulator published its AI Plan. It will "work with government and industry to ensure well-designed default regimes, such as the forthcoming guided retirement duty, can help protect members against the risks of biased or flawed AI-powered financial advice or decision-making".
One regulator relies on segmentation with AI allowed inside it; the other on a default to protect members from AI outside it. Neither is wrong. A provider with contract-based and trust-based books answers to both, for the same kind of customer, at the same moment of decision.
The human moment
The drawdown decision. 961,575 pension pots were accessed for the first time in 2024/25, and 69.4 per cent of those accesses happened without regulated advice. In the same year, Pension Wise saw 112,000 appointments. The people the new regimes are designed to reach are the people least likely to have anyone checking what they were told.
What's inside
Sixteen pages, written for an executive who knows the sector well and AI not at all:
- A note on the numbers — what is included, what was excluded, and why
- More people drawing more money, and the dashboards arriving by 31 October 2026
- The pressure point — the decision most people make without advice
- Two regulators and two different answers on AI, in their own words
- Four risks specific to pensions, none of them about the technology working
- Where AI actually is — and what the firms launching targeted support do not say
- The threat side — scams aimed at members, and errors arriving at the ombudsman
- The UK legal position, and the suitability rules targeted support sits outside
- Beyond the UK, stated as a comparator rather than an obligation
- Seven things that can be done now, none needing new law
- Three levels defined by where accountability sits, and three horizons
- An eight-workstream way in
The discipline behind it
Every figure carries a source: the FCA, The Pensions Regulator, the Department for Work and Pensions, the Money and Pensions Service, both ombudsmen, UK Finance's own data, or a provider on its own record. Pots are not people, and the briefing never turns a comparison of pots with appointments into a share of people.
A bank's commissioned survey on AI and pension planning is excluded even though a regulator quotes it — a regulator repeating a firm's figure does not make it the regulator's. Two industry AI surveys without a published sample are excluded, and so is a count of targeted support applications that rests on a journalist's request.
Who it's for
A pension provider, master trust or administrator executive who has just picked up an AI programme, a trustee board, or a leadership team launching targeted support. It assumes pensions are well understood and AI is not.
Briefing details
Frequently asked
Questions people ask before reading
Is this vendor material?
No. Every figure traces to the FCA, The Pensions Regulator, the Department for Work and Pensions, the Money and Pensions Service, the Pensions Dashboards Programme, the Financial Ombudsman Service, The Pensions Ombudsman, UK Finance's own data collection, the statute book, or a provider speaking on its own record. No vendor source appears anywhere in it.
Is it free to download?
Yes. It downloads directly, with no form and no email address required.
Does it cover advice as well as targeted support?
It covers the point of access and targeted support. Regulated advice, suitability and the ongoing review are covered in the companion briefing on AI in UK wealth and investment advice.
Why do the FCA and TPR differ?
They regulate different arrangements — contract-based pensions and trust-based schemes — and have reached for different protections. The briefing sets out both positions in the regulators' own words and does not argue that either is wrong.
How current is the research?
Verified against primary sources as at 24 September 2026, including TPR's AI Plan of 20 May 2026, The Pensions Ombudsman's annual report of 9 July 2026 and DWP's guided retirement principles of 13 July 2026. The FCA's retirement income data is for April 2024 to March 2025, because the following year's edition had not been published.
What if I want to take this further?
The briefing ends with an eight-workstream action plan. The first three — readiness assessment, use case triage, and a regulatory and legal position paper — form a natural first engagement of six to eight weeks.
Read the briefing.
Sixteen pages, free, no form. If it raises questions worth a conversation, that conversation is one message away.
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