Pensions & Retirement
FCA Authorisation
Specialist regulatory support for pension providers, SIPP operators, retirement planning advisers, and firms advising on pension transfers and consolidation.
Pensions Regulatory Landscape
The pensions and retirement sector encompasses advice on pension contributions, retirement planning, pension transfers, SIPP operations, and annuity selection. Given the critical importance of retirement outcomes, this is one of the most heavily regulated areas of financial services.
FCA regulation of pensions has intensified following high-profile pension transfer scandals, with particularly strict requirements around defined benefit to defined contribution transfers under COBS 19. The Pension Transfer Gold Standard and Consumer Duty have further elevated expectations for customer outcomes.
Successfully navigating authorisation requires demonstrating deep pension technical knowledge, robust advice processes, comprehensive safeguards for vulnerable customers approaching retirement, and evidence-based suitability frameworks that genuinely prioritize client best interests.
Typical Services
- Pension transfer advice (DB to DC)
- Operating a SIPP (Self-Invested Personal Pension)
- Retirement planning and income drawdown advice
- Annuity and lifetime income selection
- Pension consolidation and scheme comparison
- Workplace pension scheme advice
How We Support Pension Firms
- Business model scoping and permissions mapping
- Pension Transfer Specialist identification and recruitment
- APTA framework and tools implementation
- SIPP structure and non-standard asset policy design
- Professional Indemnity Insurance procurement support
- Capital planning and financial resources assessment
- Complete Connect application submission
- COBS 19 compliance manual and pension transfer procedures
- SIPP operational procedures and CASS compliance (if applicable)
- Suitability and advice process documentation
- Vulnerable customer framework for retirement decisions
- Consumer Duty implementation and outcome metrics
- FCA query management and technical responses
- Senior Manager and Pension Transfer Specialist interviews
- Additional documentation and evidence requests
- Conditional approval requirements fulfillment
- Post-authorisation compliance monitoring
- Ongoing pension regulatory advisory and updates
Required FCA Permissions
Pension firms require specific permissions based on their advice and operational activities.
Advising on Pensions Transfers
Advising clients on transferring pension benefits, particularly defined benefit to defined contribution transfers.
- Pension Transfer Specialist
- COBS 19 compliance
- Transfer Value Analysis
- Appropriate Pension Transfer Analysis (APTA)
Operating a SIPP
Operating a Self-Invested Personal Pension allowing members greater control over investment choices.
- CASS compliance
- Pension scheme rules
- Investment due diligence
- Member communication
Advising on Investments (Pensions)
Providing investment advice to pension scheme members on their pension investment strategy and asset allocation.
- Qualified advisers
- Suitability assessments
- Retirement risk profiling
- Drawdown modeling
Establishing, Operating or Winding Up a Personal Pension Scheme
Setting up, operating, or winding up personal pension schemes including stakeholder pensions.
- Pension scheme documentation
- Trustee arrangements
- Member protections
- Regulatory approvals
Safeguarding and Administration (Pensions)
Holding and administering pension assets and contributions on behalf of scheme members.
- CASS compliance
- Client money segregation
- Asset reconciliations
- CASS oversight function
Advising on Pension Income Options
Advising on retirement income options including annuities, drawdown, and uncrystallised funds pension lump sums.
- Retirement options analysis
- Annuity comparisons
- Drawdown sustainability
- Tax implications advice
Permissions & scope
Which regulated activities the firm will carry on, and the exact permissions that follow from them. Everything downstream is scoped to this, so a permission asked for loosely is a business plan and a set of controls built against the wrong thing.
Business model
What the firm does, who for, and how it earns. The FCA tests whether the model is viable and whether the permissions being requested actually match it, rather than reading the two documents separately.
Governance & SM&CR
Who is accountable for what, and whether they are fit and proper for it. Senior manager responsibilities have to be mapped to named people and evidenced, not asserted in a paragraph.
Policies & controls
The procedures that make the model work in practice, and evidence they are followed rather than filed. A policy the firm cannot show operating is the most common gap at the gateway.
Financial resources
Capital, projections and an orderly wind-down. The figures have to agree with the business model rather than sit beside it, and the wind-down plan has to be costed.
Key Regulatory Requirements
Pension firms must demonstrate compliance with COBS 19, pension transfer rules, and Consumer Duty.
Pension Transfer Rules (COBS 19)
- Appropriate Pension Transfer Analysis (APTA) for all transfers
- Transfer Value Comparator (TVC) and critical yield calculations
- Starting assumption that transfer is not in client's best interests
- Clear disclosure of costs, charges, and loss of guarantees
- Assessment of alternative options including staying in DB scheme
- Pension Transfer Specialist qualification requirement
- Detailed suitability report explaining transfer recommendation
- Ongoing suitability assessments post-transfer
Pension Transfer Specialist Requirements
- Appropriate qualifications (e.g., Pension Transfer Gold Standard)
- Demonstrated experience in pension transfer advice
- Ongoing competence and continuous professional development
- Understanding of defined benefit scheme features and protections
- Knowledge of retirement income options and drawdown sustainability
- Ability to assess lifetime cash flow and mortality risk
- Regular supervision and file reviews by competent supervisors
SIPP Operational Requirements
- CASS compliance for pension assets and contributions
- Due diligence on non-standard investments (property, unquoted shares)
- Clear member communications on investment risks and charges
- Pension scheme rules and constitutional documentation
- Annual statements and retirement option communications
- Appropriate default investment strategies
- Member data protection and information security
- Wind-down planning and business continuity arrangements
Consumer Duty for Pensions
- Good retirement outcomes for customers throughout relationship
- Products and services designed to meet customer needs at retirement
- Fair value assessment including charges and investment performance
- Clear communications about pension options and retirement risks
- Appropriate support for customers approaching retirement decisions
- Avoiding foreseeable harm from poor retirement outcomes
- Monitoring and testing customer outcomes against expectations
Vulnerable Customer Protections
- Identification of vulnerable characteristics (health, life expectancy)
- Enhanced support for customers with reduced capacity for loss
- Clear explanations for those with lower financial capability
- Flexibility in retirement planning for those with health issues
- Signposting to Pension Wise and MoneyHelper services
- Extra care for customers under time pressure or experiencing life events
- Staff training on vulnerability, mental capacity, and cognitive decline
Financial Resources and Capital
- Base capital: £20,000 for pension advice firms
- Base capital: £50,000 for SIPP operators
- Professional Indemnity Insurance: minimum £1.6m per claim
- Higher PII limits for firms advising on pension transfers
- Own funds calculation and ongoing monitoring
- Financial projections demonstrating sustainability
- Wind-down costs and orderly cessation planning
Common Authorisation Challenges
Issues we frequently help pension firms navigate during the FCA application process.
Pension Transfer Specialist Qualification
Demonstrating appropriate pension transfer qualifications and experience is critical. We help identify suitably qualified advisers, evidence relevant experience, and structure supervision arrangements that satisfy FCA expectations.
APTA and Suitability Framework
Building comprehensive Appropriate Pension Transfer Analysis frameworks aligned with COBS 19. We provide APTA templates, transfer value comparator tools, and suitability report structures that meet regulatory standards.
SIPP Non-Standard Assets
For SIPP operators, demonstrating robust due diligence on non-standard investments like property and unquoted shares. We create due diligence frameworks, risk assessment methodologies, and member disclosure protocols.
Consumer Duty Outcomes
Evidencing good retirement outcomes under Consumer Duty is challenging. We help design outcome metrics, implement monitoring frameworks, and demonstrate how products and services deliver fair value throughout retirement.
Professional Indemnity Insurance
Securing adequate PII for pension transfer advice can be difficult and expensive. We connect firms with specialist brokers, help structure risk management to improve insurability, and evidence robust risk controls.
Vulnerable Customer Framework
Implementing effective vulnerable customer identification and support for those approaching retirement. We develop comprehensive frameworks covering capacity for loss, financial capability, and health considerations.
Frequently Asked Questions
What pension transfer specialist qualifications does the FCA require?
Demonstrating appropriate pension transfer qualifications and experience is critical. We help identify suitably qualified advisers, evidence relevant experience, and structure supervision arrangements that satisfy FCA expectations.
How do you build an APTA suitability framework for pensions?
Building comprehensive Appropriate Pension Transfer Analysis frameworks aligned with COBS 19. We provide APTA templates, transfer value comparator tools, and suitability report structures that meet regulatory standards.
How do SIPP operators handle non-standard assets?
For SIPP operators, demonstrating robust due diligence on non-standard investments like property and unquoted shares. We create due diligence frameworks, risk assessment methodologies, and member disclosure protocols.
How do pension firms meet Consumer Duty outcome requirements?
Evidencing good retirement outcomes under Consumer Duty is challenging. We help design outcome metrics, implement monitoring frameworks, and demonstrate how products and services deliver fair value throughout retirement.
How do pension advisers secure professional indemnity insurance?
Securing adequate PII for pension transfer advice can be difficult and expensive. We connect firms with specialist brokers, help structure risk management to improve insurability, and evidence robust risk controls.
What vulnerable customer framework do pension firms need?
Implementing effective vulnerable customer identification and support for those approaching retirement. We develop comprehensive frameworks covering capacity for loss, financial capability, and health considerations.
Related Services
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Learn more →Ready to Get Authorised?
Speak with our pensions regulatory specialists to discuss your FCA authorisation for pension services.
Phone: 0330 133 0811
Email: contact@memaconsultants.com