In-specie pension transfers: What investors need #
Investors need in-specie pension transfers just as much as they need in-specie individual savings accounts (ISA) transfers. Retirement savings are too important to sit out of the market for days or weeks while a transfer is completed. The Retail Distribution Review (RDR) applies the same in-specie transfer principles to both pensions and ISAs. Still, for years, the reality of pensions fell well short: many providers' in-specie pension transfer services ranged from limited to non-existent.
The same infrastructure — the TeX open transfer system — supports both product types, but pension transfer volumes are much lower than ISA volumes, and pension transfers have historically taken far longer to complete than ISA transfers, in large part because so many were still processed on paper rather than online.
Inconsistent provider support: A legacy problem #
The service gap wasn't hypothetical. When this article was first published in 2019, Vanguard had just launched a strong in-house ISA transfer service while confirming its new pension product would accept cash transfers only, a decision that offered little benefit to the customer moving their retirement savings.
At the time, it wasn't entirely clear what was driving the gap. Some firms argued the RDR rules were ambiguous on pensions, even though the FCA disagreed. Industry body The Investing and Saving Alliance (TISA) initially left pensions out of the scope of its early transfer work, later reversing that decision after public criticism. A long-running dispute over pension interoperability between transfer systems TeX and Origo likely slowed progress, too. Whatever the cause, the outcome was the same: platforms weren't prioritising the customer.
PS19/29: The FCA's transfer rules take effect #
The FCA's answer was PS19/29, its policy statement on making transfers simpler. The rules removed the ambiguity by putting pensions clearly in scope, and require both the ceding and the acquiring platform to play an active role in the transfer, including making a genuine effort to offer in-specie transfers rather than defaulting to cash.
PS19/29's rules came into force on 1 February 2021, and platforms operating in the UK have now been living under this framework for several years. There's genuinely nowhere left for platforms to hide when it comes to supporting in-specie pension transfers; the obligation is explicit, not implied.
The Consumer Duty raises the bar #
PS19/29 itself hasn't been updated since 2019, but the regulatory bar it sits under has moved. The Consumer Duty, in force since July 2023, requires firms to deliver good outcomes for retail customers, not simply to tick the boxes of existing rules. For pension transfers, that means a platform can be technically compliant with PS19/29 and still fall short of the Duty if its transfer process is slow, confusing, or leaves savers guessing about timelines and next steps.
The FCA's own data shows why this matters. Average ceding times had fallen to 14 calendar days by January 2023 and continued to improve through September 2024. But the range across individual firms remains wide, from as little as 4.4 days at the fastest platforms to 29.3 days at the slowest. Under the Consumer Duty, that spread is itself a red flag: a saver's experience shouldn't depend so heavily on which platform they happen to be leaving.
For platforms, this means transfer performance is a Consumer Duty outcome that needs to be monitored, reported on, and actively improved, with clear evidence that the firm is closing the gap between its best- and worst-case transfer times.
What's next: Further reform is already underway #
The FCA isn't stopping at PS19/29 and the Consumer Duty. Its consultation paper CP25/39 proposes a new, standardised comparison process for non-advised defined contribution (DC) to DC transfers, designed to make sure savers can see valuable benefits they might lose before consolidating pots, squarely aimed at reducing convenience-led transfers that don't serve the customer's interests. The same consultation sets out a new regime for interactive digital pension planning tools, another area where the Consumer Duty is pushing firms toward clearer, more balanced communication with savers.
Wider infrastructure change is moving in the same direction. Transfer speed and interoperability, the same issues that held back in-specie pension transfers for years, are also central to newer initiatives like Pathfinder's inter-master trust transfers on ISO 20022 and SWIFT, and to the small pots consolidation agenda under the Pension Schemes Act 2026, which we cover in our small pots consolidation whitepaper. Platforms that treat transfer modernisation as a single, connected problem rather than a series of separate compliance exercises will be better placed for what CP25/39 brings next.
Robust transfer processes also depend on getting the operational basics right once a pension has moved — see our quick guide to pension payroll for what that looks like in practice.
Editor's note: this article was first published in 2019 and updated in 2026 to reflect the Consumer Duty and ongoing FCA consultation on pension transfers.
