Electronic pension transfers reached a record 1.7 million in 2025, up 70% in three years, and with the Pensions Dashboards Programme expected to drive a surge in consolidation requests, pressure on the system is set to intensify.
But while some providers now move pensions at scale in a week, others still take months to release savers' money. This is a real concern for savers, who can become trapped in underperforming funds, or stuck with a provider that doesn’t provide them with the good service, technology, tools or content that they may desire. This can leave them unable to make important decisions regarding retirement.
Drawing on insights from both its ongoing campaign to speed up pension transfers and the recent joint release of a report examining the personal pensions market (in conjunction with other leading providers), PensionBee sets out the four key reasons behind pension transfers stalling in some corners of the industry - and what needs to change to fix this.
1. An outdated legal time limit for transfers
The UK's statutory deadline for pension transfers hasn’t changed since the nineties. A six-month limit that was designed as a backstop has, in practice, become a benchmark that’s let poor performance go completely unchallenged.
PensionBee’s own transfer data for 2025 shows that whilst the fastest transfers took just five days, the slowest - including those from Cushon Master Trust and Creative Pension Trust, XPS Administration, LGPS and Capita - took between 47 and 90 days on average.
With the UK pension system overseen by two separate regulators - the Financial Conduct Authority (FCA) and The Pensions Regulator (TPR) - it’s notable that the slowest are schemes overseen by TPR, where there is the use of third-party administrators that are not caught by regulation. This divide creates a pension transfer lottery for savers, with their experience determined largely by which type of scheme they happen to be in, and which regulator they sit under.
The fix: Amending the legislation to a limit of 30 working days for straightforward defined contribution pension transfers across the whole industry would move pensions more in line with the rest of financial services, and meet modern consumer expectations. It would bite across all schemes, regardless of the regulator.
Setting a clear expectation would create accountability for pension providers and, by ending the transfer lottery, would empower savers giving them the certainty they need to engage with their retirement.
2. Misapplication of ‘amber flags’
The current transfer regulations - the Occupational and Personal Pension Schemes (Conditions for Transfers) Regulations 2021 - introduced a red and amber flag system designed to protect savers from scams. But whilst well-intentioned, the rules are too widely drafted. Some providers and third-party administrators are misapplying amber flags to perfectly legitimate transfers, for reasons such as the mere ‘presence of overseas investments’ in the destination providers’ funds, or the presence of incentives.
This misapplication presents savers with significant administrative hurdles to jump - extensive questionnaires, scams calls and safeguarding appointments with MoneyHelper, before they can move their own money. Some become frustrated and overwhelmed, others second-guess their decisions, and many give up completely. This type of ‘sludge’ practice will continue until the drafting of the legislation is fixed to remove any ambiguity.
The fix: While consumer protection is paramount, scam prevention rules must be applied proportionately, and not cause unnecessary barriers for the large volume of legitimate transfers. The Department for Work and Pensions (DWP) should amend these regulations, so that providers and third-party administrators stop unnecessarily delaying perfectly legitimate pension transfers.
Transfers to regulated, well-established schemes on an approved cleanlist should be exempt from excessive, tick-box scam questionnaires or unnecessary scams calls or appointments, allowing consumers’ rights to be respected. A streamlining of industry processes would allow providers a greater focusing of resources on genuinely high-risk transfers.
3. Paper-based processes and legacy systems
In an age of instant, digital verification, many legacy providers still insist on archaic methods, using physical ‘wet-ink’ signatures, paper transfer forms, and asking for physical ID to be sent to them in the post. This forces savers into a time-consuming loop: They have to wait for a form to arrive, sign it, then post it back. As well as adding days or weeks onto what should take seconds, it also creates added failure points. If the signature doesn't perfectly match a file from 20 years ago, for example, the transfer can be rejected, and the clock resets.
Some schemes, especially the TPR-regulated trust-based ones, have simply failed to transition from these manual processes to new IT infrastructure and systems. Combined with a lack of operational resources to process pension transfers and poor administration support services, this results in excessive transfer times.
By contrast, many modern providers using a digital platform to facilitate electronic pension transfers (e.g. the Origo Transfer Service) routinely complete transfers in under two weeks.
The fix: A digital-first presumption, where digital journeys become the default, making the process transparent from end to end, and requiring firms to "comply or explain" if they insist on manual paperwork. The technology and processes exist, are proven and already widely adopted across industry.
4. No accountability for poor performance
There is no legal requirement for providers to publish their transfer performance data, so while the best performers tend to disclose voluntarily, the slowest can hide their times, making it difficult for consumers to fairly compare different providers and make informed decisions.
Without clear service standards, there are few consequences for providers that consistently delay transfers, and little incentive to improve.
This is backed up by public demand, with 74% of consumers stating they want providers to be required to disclose their actual transfer times. Providers with slow processes face little consequence beyond reputational damage, which is often limited because consumers rarely have visibility of comparative transfer times across industry.
The fix: Greater transparency would create accountability, so all pension transfer times should be published as a service metric - this could be incorporated into the service metrics as part of the TPR and FCA’s Value for Money framework. Consumers should be able to directly and meaningfully compare the performance of different providers. Exposing this data holds poorly performing providers to account for their delays, shifting the market away from a system that currently rewards inefficiency.
Lisa Picardo, Chief Business Officer UK at PensionBee, said:“Year after year, millions of savers try to take control of their retirement savings, but they find themselves blocked by outdated processes, unnecessary red tape and excessive delays, unable to move their hard-earned money to the pension provider they choose.
“When attempts to take control of one's finances are met with obstruction, sludge or silence, trust in the entire pensions industry is severely eroded. At best, this represents an unreasonable barrier, hindering consumers’ ability to make timely decisions about their financial futures. At worst, it can have a severe emotional and human cost, actively discouraging savers from engaging with their retirement savings altogether.
"That is why we, and other leading personal pension providers, are calling on the Government to update the statutory transfer deadline to 30 working days. This is a clear, universally enforceable standard that reflects modern consumer expectations. Once this is in place, everything else will follow. The delivery of efficient pension transfers at scale can already be supported by the digital infrastructure that exists.
"Fast and secure transfers are entirely possible and already happening at scale. Many providers prove it every day. What is missing is the legislative framework to drag those that aren’t keeping up into line, and to make smooth and efficient pension transfers the norm for everyone.”
Table 1: UK electronic pension transfer volumes and values (Origo Transfer Index)
Source: Origo Transfer Index, 2025.
Table 2: Fastest Pension Providers: Average pension transfer times, 2025
Table 3: Slowest Pension Providers: Average pension transfer times, 2025
Source: PensionBee data, 2025. Based on transfer-out times for providers ceding pensions to PensionBee (with at least 100 transfers). Full list.
Read more about PensionBee’s 10-day Pension Switch Guarantee campaign here. PensionBee’s three campaign reports - A Switch In Time (May 2025), Ending Pension Purgatory (July 2025) and Faster, Fairer, Digital (January 2026) - have placed pension transfers firmly on the public and political agenda.
PensionBee’s parliamentary petition calling for Government action gained over 16,500 signatures, drawing an official response from the DWP, stating:
“The Government recognises the importance of efficiency in the pension transfers system and is considering how to improve the pension transfer process while maintaining strong member protection.
The Government’s approach is guided by two objectives, supporting efficient transfers, and crucially, ensuring strong member protections, not least against scams. We acknowledge the calls for faster transfers, and we are exploring operational improvements to streamline processes, including the use of electronic processes which can drive real improvements.
Changes driven by mandation across the market, would however, require changes to Primary legislation. We would also need to be satisfied that any changes do not weaken existing member protections or present a heightened risk of pensions fraud. Ensuring there are robust safeguards to enable members to make informed transfer choices that lead to good retirement outcomes is essential.
The last government, in November 2021, introduced the Occupational and Personal Pension Schemes (Conditions for Transfers) Regulations 2021. The regulations were intended to better protect pension savers against the threat of pension scams by placing conditions on the statutory right to transfer, through a series of red and amber flags.
A review of the regulations was published in June 2023, as agreed with the Work and Pensions Select Committee. The review concluded that although the original policy intent remains appropriate, feedback from the pensions industry suggests that the practical application of some of the provisions may have contributed to delays in certain circumstances.
In response, the Government has been working with the pensions industry to consider changes that seek to provide a smoother transfer process and proactively respond to any developing risks. DWP is planning to consult on the outcome of this work in the coming months.”
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