Operating Model Review – Delivering further OMR improvements during 2025/26

In our first blog of 2025/26, our Chief Operating Officer, Robert Loughlin, reflects on the success of the programme in year one and the key focus of the programme for the year ahead.

Our Operating Model Review (OMR) improvement programme is now in its second year and is continuing to deliver major improvements to the way in which TPO handles complaints. With complaint volumes outstripping our organisational capacity over the last five years, a record intake of new complaints in 2024, and continued challenges around our funding position, this work is more important than ever.

Results from the first year of the programme have been excellent, with a record volume of complaints concluded during the year. We will be publishing much more detail on our performance in our Annual Report and Accounts which are due to be laid in Parliament in the summer. 

The reforms that we have already implemented have been well received across the pensions industry and we have been working closely with stakeholders and with our internal teams to identify further changes that we will be taking forward this year. These will build on the gains that have already been achieved such as our revised approach to dealing with complaints that have not been through scheme level dispute resolution, our new Expedited Determination approach and expanding the use of ‘lead cases’.

OMR priorities for 2025/26

Our target for this year is to increase our closures by a further 4%, while at the same time maintaining the gains made last year. This will require everyone within our organisation to continue to work together and the ongoing support from the pensions industry.

• Improving awareness – this will support the changes that we have made around requiring scheme level dispute resolution to be completed before we accept complaints and will provide information and tools to both schemes and individual applicants to support earlier dispute resolution.
• Pensions expertise at the earliest stage of our process – we will continue to expand our pensions experience to identify and resolve complaints much earlier in our processes. We will continue to explore our thresholds to ensure we only focus on those complaints that need our help and cannot be dealt with elsewhere.
• Expedited Determinations – we will look to expand the use of expedited Determinations throughout the entire organisation. This will reduce handoffs between teams and bring forward decisions within our processes.
• Jurisdiction and formal responses – we will streamline the current process for jurisdiction decisions and when we ask respondents for a formal response to the applicant’s complaint. These processes can cause bottlenecks, and a streamlined approach will have a positive impact on reducing waiting times.
• Complex cases – a key focus of our efforts during 2025/26 will be on the large cohort of complex cases that have built up within our caseload. This will involve a focus on learning and development to increase our pensions expertise and new innovative ways of working to streamline and speed up our decision-making, including adopting shorter Opinions and Determinations. 

What does this mean for you?

If you're managing a pension scheme, these changes mean:

• a greater expectation for schemes to complete a good quality and well signposted end to end complaint process
• you’ll see an increased usage of Expedited and short form Determinations at various stages of our process
• you may be asked for formal responses earlier in our process and deadlines will be tightened up
• you’ll be provided with more customer guidance on key topics that can be shared with members.

We’ll provide more detail on changes in future OMR blogs.

Central challenge

2024/25 was an unprecedented year with the number of new complaints also growing by much more than expected. The impact that our improvements have on the historical backlog and our waiting times will largely depend on the volumes of new complaints that we receive in the months and years ahead. In 2024/25 we were only able to maintain the status quo around our waiting times, despite a Herculean effort! 

We are also working closely with our DWP colleagues to set out the case for investment in TPO. In the longer-term we will be looking for investment in our systems to enable automation and AI to transform our ways of working.

Unfortunately, there is no quick answer to the challenges that we face around the caseload and the growing volumes of complaints that we are seeing – much of which remains outside our control as an organisation. Our strategy for tackling it, however, remains clear: we will continue to increase our operational efficiency (with an aim of achieving a further 4% year-on-year improvement target for 2025/26), we will work with the sector to reduce demand wherever possible, and we will work with our colleagues at DWP and our wider stakeholders to find a long-term solution to the funding gap that we face. 

Have questions about these changes? Don't hesitate to get in touch with our stakeholder team.