What Makes a Good Pension Trustee? 4 Regulatory Tests Beyond

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Retirement Edge · Pension Governance

What Makes a Good Pension Trustee?

Fees are the easiest thing to compare, and they compound for decades, so compare them carefully. But a fee cannot tell you whether your records are right or your complaints answered. The rules set the standard for those; here are four tests, and how to apply them.

Our interest, stated upfront Standard Pensions Trust is a corporate trustee, listed on the NPRA's licensed-trustee notice dated 30 April 2026 and paid a fee for that role (Act 766, section 145). We do not grade ourselves here. Judge that interest for yourself, and apply every test below to us too. The tests are legal duties for every trustee; we found no public data ranking trustees against them, so ask each trustee for its record.

TEST 01Are the records and payments right?

A trustee keeps the scheme's accounts and a separate account for each member, valued at market value at least monthly (L.I. 1990, regulations 57 and 58).

It must pay a valid claim within thirty days where no contributions are outstanding, or within sixty days where they are (regulation 132). It must also notify members three years, and again three months, before they reach 60 (NPRA Benefit Administration Guidelines, paragraph 4).

The NPRA licenses a company only once satisfied it can administer schemes (regulation 2). These requirements make record accuracy, sound administration and timely payment important things to verify.

TEST 02Does it tell you on time, and listen?

New members must receive an information document covering fees and a named contact, and a certificate naming the trustee, within sixty days (regulations 37 and 38). Statements must follow within three months after each financial period (regulation 39).

The trustee must, as far as reasonably practicable, answer inquiries and deal with complaints (regulation 40).

The NPRA's 2024 governance guidelines also require an education and sensitisation committee on every scheme board, and an annual general meeting where members may question the scheme's affairs (Corporate Governance Guidelines, paragraphs 39 and 41(5)(c)).

We cannot say how widely both happen: ask your scheme. Check whether documents arrive when expected, whether questions receive answers, and whether members have a meaningful opportunity to raise concerns.

TEST 03Are the checks built in?

A corporate trustee needs an independent director (Act 766, section 123) and an approved compliance officer who reports directly to the NPRA and may not be dismissed for true and fair non-compliance reports (regulation 2; Compliance Officers Guidelines, paragraphs 3, 4 and 6).

The NPRA judges directors and key staff on competence, honesty and integrity, independence of mind and financial soundness (Fit and Proper Guidelines, paragraphs 5 and 6), though members cannot see that assessment.

Conflicts must be disclosed and recorded in a book members may inspect on request (regulation 44). Significant events must be reported to the NPRA within three working days (regulation 45).

When assessing a trustee, ask how independent oversight works, how compliance concerns reach the regulator, and how conflicts are recorded and handled.

TEST 04Are its fees disclosed, limited and worth it?

Fees must be disclosed to anyone applying to join (regulation 17) and may not exceed limits the NPRA sets (sections 145 and 163). Nothing may be deducted unless prescribed or authorised (section 162).

The governance guidelines ask scheme boards to oversee service providers' fees with the value received in mind (paragraph 34).

Neither a lower nor a higher fee tells you whether the other three tests are met, so check all four. None of them promises a return.

By the Numbers

NPRA notice and 2025 Annual Report; L.I. 1990. These are two snapshots from different dates. The report names none of the 22 trustees. These are legal clocks and sector figures, not a rating of any trustee.

29 Corporate trustees named on the NPRA's licensed-trustee notice dated 30 April 2026.

22 of 29 Corporate trustees operating in 2025 that met all regulatory requirements, according to the report. The trustees are unnamed.

30 days To pay a valid claim where no contributions are outstanding (regulation 132).

3 working days To report a significant event to the NPRA (regulation 45).

Key Takeaway

Compare fees, then check the floors: records and payments right, information on time, checks built in, and fees disclosed and within limits. Every test applies to us too.

What You Should Do Next

For Members

Check your own documents against the clocks in regulations 37 to 39 and keep the dates. Ask to inspect the conflicts record book (regulation 44), and attend your scheme's annual general meeting or ask how to put a question in writing.

If your employer chose the scheme (regulation 156; section 129), members still nominate at least a third of the trustees or of a corporate trustee's directors, subject to exceptions (sections 141 and 142). If a test fails, use the complaint route below and tell your employer.

For Employers

Choosing or reviewing a master trust? Ask each trustee in writing for its fees (regulation 17), its record against the payment and statement clocks, and how its compliance officer reports. Check the NPRA's lists at npra.gov.gh under Trustees, and check their dates. A lapsed list proves nothing.

For Tier 3 Savers

A personal pension scheme is your choice, and your employer must provide the payroll services to join it (section 115). Before choosing, check the NPRA's lists, ask for the fee disclosure you are owed as an applicant (regulation 17), and ask in writing how members raise questions.

If a Trustee Falls Short

Write to the trustee first (regulation 40). The NPRA receives and investigates complaints of impropriety (section 7), and a member or beneficiary may ask the NPRA Board in writing to review a trustee's decision (section 202).

What Makes a Good Pension Trustee? 4 Regulatory Tests Beyond Fees