Pension transfers: what's changing for UK pension trustees?
Published on 11 November 2026
Trustees can expect new rules from April 2027 to reshape transfer checks and tighten those on self-administered schemes
At a glance
A new reputable scheme route and removal of the overseas investment flag.
Members consolidating pension pots could face fewer repeat guidance appointments.
New safeguards to help protect members transferring to small self-administered schemes.
The government has published the response to its recent consultation on reforming the pension transfer rules to introduce a simplified "reputable scheme" route for low-risk transfers and change the scam-protection warning flags that trustees assess.
The new rules and supporting guidance are expected to apply from April 2027.
New reputable scheme route
Trustees will not need to check for red or amber flags if they are satisfied that the receiving scheme is reputable.
The Department for Work and Pensions and The Pensions Regulator will develop a non-exhaustive list of factors to help trustees decide whether a receiving scheme is reputable.
No more overseas investment flag
In cases where trustees do need to check for red and amber flags, overseas investments will no longer trigger an amber flag in their own right. Other flags, including those for high-risk or unregulated investments and unclear, complex or unorthodox investment structures, are expected to provide sufficient protection. The incentives flag will also remain.
Less repeat guidance
Members will not normally need to repeat Money and Pensions Service (MaPS) guidance if they have already taken it within the previous 12 months. This should help members who are consolidating multiple pension pots, but transfers to a small self-administered scheme (SSAS) will be an exception. This reflects government concerns that "the SSAS model may be vulnerable to those seeking to abuse the system". It notes that some savers may have been exposed to high‑risk or unregulated practices, investments in non‑standard assets, and arrangements seeking to present pension liberation activity as legitimate investment opportunities.
Employment-link and SSAS-transfer rules
The absence of an employment link between the member and an employer in the receiving occupational pension scheme will become a red flag, rather than an amber flag. This is intended to help tackle misuse of SSASs.
For some legitimate SSAS transfers, members may be unable to provide evidence of a salary link. Guidance will explain what other information and evidence trustees may consider when applying this flag.
A new amber flag will also apply to transfers to a SSAS where an employment or other relevant relationship has been demonstrated. In these cases, members will need to attend a MaPS guidance appointment before the transfer can proceed. The appointment aims to make sure that the member understands the "responsibilities, governance requirements and potential liabilities associated with participation in a SSAS". Members can then confirm whether they wish to proceed with their transfer.
Osborne Clarke comment
The changes raise practical questions for trustees to discuss with their scheme administrators.
Discussions could cover the need for training on the changes and what they mean in practice, and agreeing how to approach the new reputable scheme and employment link rules.
Transfer procedures, checks, forms and member communications may also need reviewing and updating. However, some of these steps may depend on when the final regulations and supporting guidance are available. The existing requirements will continue to apply until the changes take effect.
