In its response to the FCA’s consultation on adapting requirements for a changing pensions market (CP25/39), PensionBee said that while it welcomes the regulator’s focus on improving non-advised DC transfers, reform will only succeed if it captures FCA-regulated firms, TPR-regulated schemes and the third-party administrators (TPAs) that process transfers behind the scenes.
One system, one standard
PensionBee argues that from a consumer perspective, regulatory boundaries are invisible – yet they currently dictate the transfer experience. Many of the slowest transfers originate from occupational schemes regulated by TPR and frequently administered by external TPAs, which sit outside the FCA’s direct rule-making powers.
The firm is therefore urging coordinated action between the Department for Work and Pensions (DWP), the FCA and the TPR – backed, if necessary, by primary legislation – to create a single, consistent transfer framework. Without alignment, PensionBee warns, savers could face different rules, timelines and standards depending on which type of scheme they are transferring from – a fragmented approach that risks consumer confusion, operational complexity and continued delays.
Public backing for reform
The call follows PensionBee’s 10-day Pension Switch Guarantee campaign, which included three industry reports and a Parliamentary petition signed by 16,729 people across all 650 UK constituencies, receiving a Government response.
Research underpinning the campaign found:
46% of savers who have transferred described at least one experience as “difficult”.63% believe slow transfers prevent effective retirement management.63% support a legally mandated maximum transfer timeframe.
PensionBee says these findings demonstrate strong consumer appetite for enforceable standards - not voluntary guidance.
A 10-day guarantee for all schemes
In its submission stating the importance of a single, industry-wide process covering all DC schemes and administrators, PensionBee also reiterates its call for a universal 10-working day Pension Switch Guarantee, alongside:
A mandate for digital transfers and universal acceptance of electronic signatures.
Publication of transfer times as a service metric within the forthcoming Value for Money framework.
Urgent reforms to the 2021 Transfer Regulations to reduce unnecessary delays caused by the misuse of the pension transfer scams legislation.
Reducing the statutory six month transfer deadline.
The company argues that limiting reforms to FCA-regulated providers would leave a significant proportion of transfer activity untouched - particularly as many consolidation journeys involve moving savings from dormant workplace schemes into personal pensions.
Lisa Picardo, Chief Business Officer UK at PensionBee, said: “Savers don’t understand – and shouldn’t need to understand - whether their pension is regulated by the FCA or TPR. They just expect their hard-earned savings to be moved quickly, safely and without unnecessary barriers, when they’re trying to take control of their retirement.
“If reform only applies to part of the market, we risk creating a two-tier transfer system. That would be confusing for consumers, ineffective in practice and may end up creating more problems than it solves. The only way to truly fix pension transfers is to extend a clear, enforceable standard across the whole industry - including occupational schemes and the third-party administrators who process transfers on their behalf. One system. One standard. One timeframe.”
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