4 November 2026
If you are covering the government’s consultation response on proposals to amend the Occupational and Personal Pension Schemes (Conditions for Transfers) Regulations 2021, please see the following comment from Jon Greer, head of retirement policy at Quilter:
“After years of calling for change, it is encouraging to see the government has listened to the concerns raised by the industry and pension savers. The transfer rules are supposed to provide a safety net against scams, not become a roadblock for people simply trying to move their pension. While they were introduced with the right intention, in practice they have too often caught perfectly legitimate transfers, causing unnecessary delays and frustration. The direction of travel is positive, although the devil will ultimately be in the legislative detail.
“Having long since lobbied for its removal, confirmation that the overseas investments amber flag will go is particularly welcome. Its scope was far too broad, meaning ordinary features of pension arrangements could trigger additional checks even where there was little indication of a scam. Removing it should make a meaningful difference to the transfer experience for many savers and allow schemes to concentrate their resources where there is genuine cause for concern.
“The proposed changes around SSAS transfers are also more pragmatic than the original proposals. We were concerned that making the employment link a red flag could inadvertently prevent legitimate transfers for director and business owners who may not receive a conventional salary or make regular employer contributions. A payslip is not a proxy for whether a pension transfer is legitimate, so it is welcome that the government has recognised this problem and intends to allow a wider range of evidence to demonstrate the necessary relationship.
“The additional amber flag requiring guidance for SSAS transfers also provides a useful extra safeguard. However, an employment link can only ever be one indicator of risk and does not address all of the wider concerns associated with some SSASs, including governance, unregulated investment activity and whether members fully understand the responsibilities they are taking on as trustees. There remains a wider question about whether the regulatory framework around SSASs provides savers with sufficient protection.
“It is also positive that straightforward transfers to reputable schemes should have a clearer route through the regulations. Protecting savers from scams and allowing legitimate pension transfers to proceed efficiently should not be competing objectives. Done well, these reforms should reduce unnecessary friction while allowing providers to concentrate their efforts where the risks are real. We will now need to see the final regulations and guidance to understand exactly how the new regime will work in practice.”
