Every pension scheme has members it cannot find. Most have a number for them, a percentage of deferreds with no confirmed address, that appears in the annual data report and the scheme return. Fewer can say what they have done about those members, when they did it, and what happened next.
That second question is the one that matters when something goes wrong. A member reaches retirement age and cannot be contacted. A pension goes unclaimed for years and the arrears become a complaint. A payment lands at an old address. In each case, the question a regulator, an ombudsman or an auditor will ask is whether the trustees took reasonable steps.
"Reasonable steps" has no fixed definition. It does have a shape, and it is easier to meet than most schemes think.
In short: reasonable steps for gone-away members means tracing on a set cycle, verifying uncertain results with the member, passing unresolved cases to manual tracing, and recording every step. Members past retirement age whose pension is due but unpaid come first, because the scheme already owes them money. The trustees set the frequency at their annual data review.
What the regulator expects
The Pensions Regulator consolidated its member data guidance at the end of 2025. As summarised by Broadstone, it expects administrators to "conduct regular reconciliation, tracing, mortality screening" and to develop and run data improvement plans. Trustees are expected to oversee that work: to receive data quality reports, to submit common and scheme-specific data scores in the scheme return, and to assess the need for a data review at least once a year.
The guidance does not give a tracing frequency. That is deliberate. A small closed scheme with a stable pensioner population has different exposure from a large scheme with tens of thousands of deferreds who left employment in the 1990s. What TPR does expect is a decision, made by the trustees, that reflects the risk in their own membership.
Why gone-aways matter more now
Three things have changed the stakes since most schemes last ran a full trace.
The first is pensions dashboards. Every scheme in scope must be connected by 31 October 2026, and the MoneyHelper dashboard is expected to open to the public in 2027/28. Members the scheme has lost will start finding the scheme on their own, and will expect a quick and accurate answer when they do.
The second is the growth of member-side tracing. Raindrop, a consumer pension-finding service, reported tracing 61,858 lost pots in the first quarter of 2026, up from 10,361 a year earlier. Members are being reunited with old pensions through routes the scheme does not control.
The third is scale. The Pensions Policy Institute estimated in 2024 that 3.3 million pots worth £31.1bn had been lost across the UK. Its 2026 research extends the work to defined benefit schemes for the first time, and is due to report this autumn.
A gone-away deferred member used to be a quiet line in a spreadsheet. Increasingly, they are a phone call waiting to happen.
A tracing cycle that holds up
The schemes in the strongest position tend to follow the same broad sequence, repeated on a set cycle and recorded each time.
It starts with a clean list. Deduplicate the membership, flag every record with no address or an address marked as returned mail, and split the result into three groups. Members who have passed normal retirement age without claiming, or whose pension in payment stopped when the scheme lost contact, come first. Deferreds approaching normal retirement age come next, then everyone else.
The first group gets priority because the scheme already owes them money. Schemes account on an accruals basis under the Pensions SORP, so pension instalments that have fallen due but not been paid are recognised as a current liability in the scheme accounts. That liability grows with every instalment the member misses, and the arrears are what turn a lost member into a complaint.
Next comes automated tracing. Address tracing services match member records against credit reference data, electoral roll data and other sources, and return a new address with a confidence level. High-confidence results can usually be accepted. Lower-confidence results should not be loaded straight onto the record.
The tool matters here. Tracing providers draw on different data and score confidence differently, so the share of usable results varies. MM, the data partner behind Navro's tracing service, reports 25% more usable, high-confidence results than competing tracing tools.
Those uncertain results need verification. Contacting the member at the suggested address, asking them to confirm their identity and details, turns a probable address into a confirmed one. Skipping this step is how schemes end up writing to the wrong person, which carries its own data protection risk.
Some members will still be missing. For those, manual or forensic tracing by an experienced team can resolve cases that automated matching cannot: members with common names, changed names, or long periods overseas.
Finally, write it down. Record what was run, when, against which population, what came back, and what was done with the results. This is the part most schemes underinvest in, and it is the part that answers the reasonable steps question.
How often is often enough?
There is no single answer, but a defensible approach usually includes an annual trace of members with no confirmed address, continuous tracing of every member whose pension has fallen due but not been paid, a targeted trace of deferreds in the five years before normal retirement age, and a trace before any event that depends on accurate data: a valuation, a buy-in, a benefit change, or the run-up to dashboards going public.
Schemes with large overseas populations, or a history of returned mail, should consider running these more often. The trustees' annual data review is the right place to set the frequency and record why.
Where tracing meets payment
Finding a member is not the end of the job. A member traced at 64 will soon need paying, and the address, identity and bank details used for that payment all depend on the trace being right.
This is where many schemes lose the thread. The tracing supplier produces a file. The administrator loads some of it. The payment provider receives an instruction months later, with no link back to how the member's details were confirmed. If the payment fails or reaches the wrong person, the audit trail is split across three organisations.
A scheme that can show a single record running from trace to verification to payment confirmation has a much simpler answer to give.
Navro links address tracing, verification and manual forensic tracing to payment execution on one platform, so the steps a trustee takes to find a member sit in the same record as the payment that follows. See how member data tracing works.
Frequently asked questions
What is a gone-away member in a pension scheme?
A gone-away member is a scheme member whose current address the scheme does not hold. Most are deferred members, but the group also includes members past normal retirement age whose pension has fallen due and gone unpaid. Post sent to their last known address is returned or goes unanswered, so the scheme cannot contact them about their benefits.
How often should a pension scheme trace members?
The Pensions Regulator does not set a fixed frequency. It expects administrators to carry out regular tracing and mortality screening, and trustees to review data quality at least annually. Many schemes trace members with no confirmed address every year, and give closer attention to two groups: members whose pension has already fallen due but has not been paid, and deferred members approaching retirement age.
What happens to pension payments owed to a member the scheme cannot find?
The scheme still owes them. Under the Pensions SORP, instalments that have fallen due but not been paid are recognised as a current liability in the scheme accounts, and the arrears keep building until the member is found and paid. That is why these members should sit at the top of any tracing programme.
What counts as "reasonable steps" to find a missing pension member?
There is no statutory definition. In practice, reasonable steps usually means running automated address tracing, verifying uncertain results with the member, using manual tracing where automation fails, repeating the exercise on a set cycle, and keeping a clear record of each step and its outcome.
What should trustees do when a traced address is low confidence?
A low-confidence result should be verified before it is loaded onto the member record. That normally means contacting the member at the suggested address and asking them to confirm their identity and details. Writing to an unverified address risks sending personal data to the wrong person.
Do pensions dashboards solve the gone-away problem?
Only partly. Dashboards help members who choose to search for their pensions. They do not give schemes a forwarding address for members who never search, so schemes still need their own tracing programme.
Sources: Broadstone: TPR record-keeping guidance briefing (March 2026) · Mallowstreet: TPR updates member data guidance · Pensions Expert: PPI widens lost pensions survey to include DB schemes · The Pensions Regulator: Pensions dashboards guidance
