London, 21 July 2026: PensionBee, a leading online retirement savings provider, has welcomed the Government’s proposed changes to the pension transfer regulations as a positive step forward, and urged it to proceed swiftly to reduce unnecessary friction and frustrating delays for savers trying to move their retirement savings.
PensionBee’s formal response to the DWP's consultation on amending the pension transfer regulations backed its proposals, but cautioned that clearer supporting guidance was necessary for the successful implementation of reforms, and that continued collaboration and engagement between DWP, TPR, FCA and industry would aid the consistency of practical application to benefit consumers.
The submission backs DWP proposals to introduce a “reputable scheme” test as part of the First Condition, a mechanism that would allow the vast majority of straightforward pension transfers to proceed efficiently, without triggering the existing flag-checking process that leave consumers frustrated in the case of perfectly legitimate pension transfers, instead reserving resources and scrutiny for cases that warrant it where genuine scams risk exists.
PensionBee calls for clear, objective criteria to underpin this test, with a starting list of scheme types that should be considered reputable by default, preventing schemes and providers from applying the test inconsistently or incorrectly, at the expense of savers. In addition to those already processed under the First Condition, these should include FCA-authorised personal pension and SIPP operators with sufficient operating track-record and without FCA restrictions in place, TPR-supervised master trusts, and any scheme ultimately wholly-owned and operated by a UK publicly listed company (or equivalent).
PensionBee has also called for a formal mechanism requiring ceding schemes to notify all parties (including the receiving scheme, the DWP, the relevant regulator and the consumer), when they reject a receiving scheme for not being “reputable”, creating transparency and accountability in how the test is applied in practice, and to allow action to be taken.
PensionBee supports the proposed new red flag for Small Self-Administered Scheme transfers in principle, but cautions that it could unintentionally hinder legitimate transfers in some cases. Without clearer guidance on what counts as acceptable evidence of an employment link, savers with less conventional arrangements, including directors who take income as dividends, consultants, non-executive directors, retirees and deferred members, risk being blocked by a rule designed for cases where no genuine link exists at all. PensionBee calls on DWP and The Pensions Regulator to publish guidance alongside the amended regulations, setting out what evidence is sufficient and how trustees should handle cases where evidence is incomplete or difficult to verify.
Lisa Picardo, Chief Business Officer UK at PensionBee, said:
“Pension transfers have been broken for too long with savers being blocked from consolidating their own savings and optimising their own retirement outcomes by rules that were designed to protect them, but have become a source of harm in their own right.
“The DWP proposals to reform the pension transfer regulations are a long overdue but meaningful step forward in the right direction, with the introduction of the “reputable scheme” test that should allow the vast majority of straightforward pension transfers to proceed, the removal of the “overseas investments” amber flag that has unnecessarily been sending consumers into lengthy MoneyHelper loops for years, and the introduction of the Small Self-Administered Schemes red flag.
“But to ensure the policy objectives are achieved and to maximise the success of the proposals, clear guidance must be provided by the DWP to see these changes be applied consistently and correctly by the industry. The DWP must ensure they are not replacing one form of delay with another.”
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