Reflections on first Own Risk Assessments
On 10 June 2026, the UK retirement landscape saw a ‘double dose’ of publications designed to unlock an estimated £160 billion tied up in defined benefit (DB) pension schemes.
With the first wave of Own Risk Assessments (ORAs) now completed for schemes with 31 March and 5 April deadlines, this feels like a good time to reflect on the experience so far. While the process has been somewhat time consuming, it has also provided some useful insights (both in terms of meeting the new requirements and in reaffirming the strength of existing governance frameworks).
The general code has raised expectations, especially around how clearly governance needs to be documented and evidenced. In practice though, this hasn’t been about starting from scratch. It’s been more about pulling together what you already do well and showing it in a more structured way. Reassuringly, the process has confirmed that our schemes are already operating to a high standard of governance. Saying that, I do believe the ORA process has been a really valuable exercise and will continue to help us drive the standards that members deserve.
Building on what’s already there
In reality, most of the key building blocks were already in place by the time it came to preparing the first ORA for many of our schemes. This was partly due to how they were already governed and partly as a result of the Effective System of Governance (ESOG) gap analysis and subsequent work that has been undertaken over recent years. The policies, processes and governance frameworks we’d put in place were working as intended, and this reinforced how the ESOG and ORA requirements are designed to work together.
The real shift has been moving from “we do this” to “we can clearly evidence how and why we do this.”
Proportionality is key
One of my biggest takeaways has been the importance of proportionality. The ORA isn’t a one-size-fits-all exercise, and this has been particularly evident when working across schemes with different structures and levels of complexity.
Taking a proportionate approach has helped keep the focus on what really matters for each scheme, making the process more manageable and more meaningful overall.
A helpful safety net
An added benefit of the process has been how it acts as a bit of a safety net.
Stepping back and looking at everything holistically has helped spot areas that just needed a quick sense-check. Small things like ensuring documents are publicly available and up to date that could have been missed. It’s given a level of confidence that everything is where it should be, with no gaps.
Embedding it into business as usual
Now that the first ORAs for March and April deadlines are complete, the focus has shifted.
The ESOG Planner is now fully embedded and reviewed quarterly alongside the business plan. That regular cycle acts as a trigger for any updates or more detailed reviews.
The nature of how policies and procedures are reviewed has also evolved and we need to consider how they actually work in practice, for example:
- Did it do what it was supposed to do?
- Was it useful in practice?
- How could it be improved?
That shift has led to more formalised moments of reflection and review, which then creates better outcomes as a result.
A continuous cycle
Having completed this first round, the schemes we support are in a strong position going forward. Over time, the ORA will become less of a standalone task and more of a continuous improvement cycle, with each review feeding into the next in a much more natural way. Many schemes will find their first ORA to be the most labour intensive one.
The ORA process has reinforced the strength of our existing governance, while also helping us take a more structured and thoughtful approach going forward. Overall, it’s a reminder that good governance isn’t just a compliance exercise, but something that generates better outcomes by creating well-run, effective schemes.
Want to learn more?
Get in touch with Kat or learn more about how we can help with own risk assessments.
