FORTHCOMING DEVELOPMENT: On 15 December 2025, the Department for Work and Pensions (DWP) launched a consultation examining whether the existing powers enabling the Pensions Regulator (TPR) to remove and replace trustees should be supplemented or reformed, noting that TPR’s current statutory powers to suspend, prohibit or replace trustees are tightly constrained, used infrequently and can involve complex, quasi-judicial processes. Where trustee replacement is required, TPR generally appoints independent trustees from its independent register, which in practice consists of a small number of professional trustee firms and can be an effective but costly solution, particularly for schemes under stress or orphan schemes with no trustees in place. Against this background, the consultation explores the feasibility of introducing a government-appointed public trustee to act as a secure, independent, last-resort option where trustees need to be replaced or appointed. Moreover, where applicable, a scheme must comply with legislative requirements relating to the appointment of member-nominated trustees or directors. Legislation (the ‘Member-nominated trustees (MNT) legislation’) requires that at least one-third of trustees are member-nominated trustees (or