The process for transferring your benefits out of the Scheme has changed. The Trustee must now check whether your transfer meets one of two legal conditions: the First Condition or the Second Condition as listed below.
If neither condition is met, you won’t have a right to transfer under the law, and we’ll let you know.
What the law says
To transfer your pension benefits by law, one of two conditions must be satisfied by the receiving scheme.
First Condition
The First Condition is met if your transfer is to:
- An authorised master trust,
- A public service pension scheme, or
- An authorised Collective Defined Contribution (CDC) scheme.
Second Condition
The Second Condition involves checking for “red” or “amber” flags, as set out in legislation. This often means we’ll need more information from you or the receiving scheme.
Extra checks are needed if you’re transferring to:
- An occupational pension scheme (that doesn’t meet the First Condition), or
- A qualifying recognised overseas pension scheme (QROPS).
In these cases, we may also need information from your employer to confirm your employment link or tax residency. If we need anything further, the Scheme Administrator will contact you.
- No clear employment link with the new scheme’s employer.
- High-risk or unregulated investments.
- High or unclear charges.
- Complex or unusual investment structures.
- Overseas investments in the receiving scheme.
- A sudden rise in transfers linked to the same scheme or adviser.
If an amber flag is found, you’ll need to book a free pension scams guidance appointment with MoneyHelper and provide proof you’ve attended.
Red flags include:
- Not providing the information we ask for.
- Not taking MoneyHelper guidance when asked.
- A regulated activity being conducted without the right authorisation.
- Being contacted out of the blue (by phone, text, or email) about pension transfers.
- Being offered an incentive to transfer (unless it’s part of an employer-led exercise).
- Feeling pressured to transfer.
If a red flag is found, you won’t be able to transfer under the law, and we’ll confirm this to you.
How this affects your transfer
When we receive your completed transfer forms, we’ll check if either the First or Second Condition is met. If we need more information, we’ll get in touch — and your prompt response will help keep things moving.
- If your transfer is to an occupational pension scheme, you’ll need to show evidence of your employment link.
- If there’s a red flag, your transfer can’t go ahead.
- If there’s an amber flag, the transfer may still be possible, but you must complete MoneyHelper guidance first.
Please note that transfers can sometimes take longer due to these checks. If there are any delays, the Scheme Administrator will keep you updated.