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FCA consultation on improving transfer process

by Emma Simon
December 11, 2025
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The FCA has issued a new consultation on modernising pension tools and updating transfer times to further improve the DC market.

Under the proposals, firms would be required provide better online planning tools and to offer a simple, side-by-side comparison of key features before a transfer — including charges, investment approach, retirement options and any safeguarded benefits that may be lost. 

Ceding providers would have up to 10 working days to supply this information, with receiving firms then given three days to present the comparison to the customer before any instruction can be made.

The consultation has been welcomed by those in the industry. Quilter head of retirement policy Jon Greer says: “These FCA proposals are a welcome step toward making pensions clearer and safer for everyday savers but they do come with trade offs. 

“The plan to modernise online planning tools should help people see, in plain language, how paying in more, retiring a little later, or choosing a different way to take income could change life after work. That is positive, but it only works if providers keep assumptions realistic, show figures in today’s money, and make it clear that projections are estimates rather than promises.”

However he adds that the second change proposed could slow pension transfer times. “Before you move or combine pensions, you would receive a simple side‑by‑side comparison between the new and old scheme of the things that count. That means fees and charges, the investment approach, the options you will have at retirement, and any valuable benefits you might lose by switching. This extra pause can prevent costly mistakes, especially as dashboards help more people find old pots.

“But consumers need to understand the trade‑off. The new process will add time to transfers,  significantly so in some cases. Your current provider may take up to 10 working days to send information to the firm you are thinking of moving to. That firm then has three working days to replay the comparison to you, and only after that can you instruct a transfer. In practice, legacy systems and extra checks can stretch timelines further. If implemented someone planning to consolidate or access money soon, should allow several additional weeks and do not assume a quick, one‑click transfer.”

Greer welcomes that the FCA is proposing a “pragmatic carve-out” for small inactive pots worth £1,000 or less. But he adds: “There is also a proposal for the customer to opt out of the process entireley. We note that the FCA believe opt-outs will be the minority exception and will conduct consumer testing to test this.”

Others in the industry have welcomed these proposals, saying that requirements for firms to provide this information within 10-days may actually speed up some transfers, with some firms currently taking longer to provide just basic information. 

PensionBee described the proposed changes as a “vital package of reforms” that would remove long-standing friction in the market.

It says the FCA’s plan to enforce a 10-day response time for ceding providers and mandate the acceptance of digital signatures marks a long-awaited shift away from “outdated, paper-based processes”.

PensionBee chief business officer UK Lisa Picardo says: ““The industry has been plagued by excessively slow transfer times, inconsistent practices, and providers that routinely reject perfectly valid digital signatures. These reforms set a clear and enforceable expectation: consumers should be able to move their pensions efficiently, securely and without unnecessary friction.”

However she adds that these reforms need to apply across both FCA- and TPR-regulated schemes to avoid new inconsistencies, noting that TPR-regulated providers account for around 30 million DC memberships.

She urged regulators to align their approaches and called for separate reform of the DWP’s transfer regulations — particularly the misused ‘amber’ and ‘red’ flag rules — with a consultation expected in 2026.

She adds: “A clear, simple 10-day pension switch guarantee could set expectations for consumers and providers alike – we know many firms are already able to work to this timeframe consistently already.”

Both PensionBee and Quilter said that with pensions dashboards expected to increase transfer activity in future, it was important for a consistent rules to enable faster, digital-first processes.

PensionBee also called for the mandatory MoneyHelper appointments should now become voluntary, once this additional information is provided during the process itself, although she added that access to this free service should continue to be signposted to members when transferring or consolidating pensions. 

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