The Malta Independent 16 July 2026, Thursday
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Governance, not design, will make automatic enrolment work

David Spiteri Gingell Sunday, 16 November 2025, 07:22 Last update: about 9 months ago

Automatic enrolment (AE) is on its way.  It is the biggest pension change Malta has seen in twenty years.  It will shape how we save for the future - and show how ready our institutions are to manage that change.  We have one chance to get this right.  If it starts on solid ground, it will stand for decades.  If it starts weak, people will lose faith and stop joining.  Once trust is broken, it is hard to win back.

Earlier this year, the Ministry for Finance said it prefers a trust-based system for automatic enrolment.  This matters.  It places people's savings under trustees who, by law, must act solely in members' interests.  This fiduciary duty is a legal promise to protect savers' interests, not those of government or business.  Unlike other pension types that depend on company behaviour or regulatory responses, a trust-based model embeds accountability into its structure. Trustees must justify their decisions and are legally answerable if they fail to do so. Yet structure alone is not enough. Trustees must be skilled, independent, and properly supervised. The law is only as strong as those who apply - and enforce - it.

Independence is the first test. Trustees do not represent any company or group. They stand for the saver, with no side interests. They must be chosen for skill, honesty, and courage to question decisions.  Governments come and go, but trustees stay. Savers deserve that steady hand.  The second test is openness. Good management is not a once-a-year job - it must happen every day.  Trustees must oversee investments, fees, communications, and risks. Clear records and regular reporting show savers how their money is managed. Openness builds trust; hiding facts destroys it.

The third test is long-term care. AE is not just about signing up - it is about retiring safely.  Most people will stay in the default fund, so it must protect their dignity, keep risks in check, and avoid needless costs.  Being careful does not mean avoiding growth; it means steady, smart decisions for the saver. Good management also needs teamwork. Trustees, regulators, fund managers, and administrators all share responsibility. Each must be open and accountable.  If one link fails, the whole chain weakens. A trust-based system makes sure everyone plays by the same rules.

The United Kingdom offers a clear example. Since 2012, both trust-based and contract-based pension schemes have operated under strong, equivalent governance rules. From 2014, cost transparency and charge caps became standard, backed by annual reporting. Over time, focus has shifted to value for money and visible accountability. When fiduciary duties are embedded and supervision is strong, governance adapts and stays transparent to savers.

For Malta, the lesson is to embed governance from the start, not as a corrective measure later.  The supervisory authority must have the expertise and resources to inspect, intervene, and enforce. Fit-and-proper testing, annual governance statements, and public reporting will create a culture of accountability. The goal is not bureaucracy, but confidence - the knowledge that savers' interests come first. Education matters too. Trustees, employers, and those running the system must understand what fiduciary duty really means - acting for others, not themselves.  Ongoing training and checks will keep the system honest and respected. When good practice becomes routine, trust follows.

Within Malta's scale and institutional setting, the government's preference for a trust-based model points to an effort to embed clearer accountability in pension governance. Concentrated markets and varying financial capability call for professional stewardship that is legally bound to act for members, not commercial intermediaries. By internalising accountability within trusteeship, the model builds discipline and coherence across the system. Decisions stay where expertise and legal duty meet.

The real test will come years from now, when the first workers retire under it. Results, not announcements, will matter most. Day-to-day management, not declarations, will decide success.  We often talk about coverage, participation, and how much people save. All are important.  But without good management, these goals stay on paper. Governance - strong, honest, transparent governance - makes them real.

AE will work only if it is managed with independence, openness, and long-term vision. A trust based model, as proposed by the government, has string merits - above all, its focus on accountability and fiduciary duty - buts its success will depend on hos firmly those principles are applied. This reform is more than a new rule; it is a promise of integrity. Numbers will not measure its success, but by whether every worker can retire knowing their pension was safe, fair, and worthy of their trust.

 

David Spiteri Gingell specialises in governance, pensions, and institutional reform

 


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