10 red flags in a pension lead source, and the rule behind each

With most bought leads, the worst that usually happens is wasted money: numbers that don't pick up, people who've already been rung by four other firms. Pension leads carry that risk too, but they carry a second one. A bad pension lead source can put your firm next to cold calls, scam-style adverts or an introducer steering people towards a transfer, and the FCA expects you to have checked for all of that before you took the introduction.

So this is a list of red flags written for advisers, compliance officers and principals. Each one comes with the rule behind it and a source you can check.

What is a red flag for a financial adviser?

It depends which side of the desk you're on.

For consumers, the FCA's pension scams page lists the warning signs: promises of "a guaranteed better return on your pension savings", "high-pressure sales tactics", "unusual investments, which tend to be unregulated and high risk", "complicated structures" and "several groups (some of which may be based overseas) all taking a fee". It also says: "Professional advice on pensions is not free."

For advisers buying leads, a red flag is anything suggesting the prospect in your diary got there through a route you couldn't defend to the FCA, the ICO or the client. The FCA's alert on unauthorised introducers and lead generators tells firms to do "robust due diligence on the introducers you transact with" and to check introductions were "sourced legitimately". The list below is what that looks like in practice for pension work.

What are the 10 red flags in a pension lead source?

The short version first, then each one in detail.

1. The supplier phones people about pensions who didn't ask
2. The adverts present pension advice as free
3. The data is recycled, aged or bought in
4. The consumer doesn't know which firm will contact them
5. Nobody checks the pension value
6. The introducer does fact-finds or risk questionnaires
7. The funnel pushes defined benefit transfers
8. The introducer is paid more depending on what the client does
9. There's no consent record you can see
10. It claims to be "FCA compliant" or regulated when it isn't

1. The supplier phones people about pensions who didn't ask

A call centre working a list, a "we're following up your enquiry" call to someone who never enquired, a "qualification" call nobody asked for. Any of these is the first thing to rule out. A call the person specifically asked for (a callback they booked, say) is solicited, and the ICO treats it differently, but the request needs to be specific and recorded.

The ICO has fined firms for exactly this. CPS Advisory was fined £130,000 in September 2020 for more than 100,000 unauthorised pension calls. EB Associates was fined £140,000 in December 2021 for 107,003 pension calls, and it had been paying third-party lead generators up to £750 per referral. The Data (Use and Access) Act 2025 raised the maximum PECR fine to £17.5 million or 4% of worldwide turnover from 5 February 2026.

The rule: regulation 21B of the Privacy and Electronic Communications Regulations, in force since 9 January 2019. An unsolicited live marketing call about a pension is only allowed if the caller is an FCA-authorised firm or a pension scheme trustee or manager, and the person consented to calls from that caller or has an existing client relationship. A lead generator is neither, so it can't make unsolicited pension marketing calls. Making them on your behalf doesn't change that.

Source: The Privacy and Electronic Communications (Amendment) (No. 2) Regulations 2018; ICO guidance on live calls; ICO on DUAA commencement.

2. The adverts present pension advice as free

A no-cost "check" of your old pensions, "find out if you're owed money", "see what your pension could really be worth". These are the hooks the FCA has spent years warning consumers about, and they attract the people least likely to pay for advice.

A free first meeting isn't the problem. Plenty of firms don't charge for an initial conversation. The problem is an advert that presents advice as free, or uses a no-cost review as bait. Ask to see the adverts that are running now, not a sample from last year.

The rule: financial promotions must be fair, clear and not misleading, and an unauthorised firm can only communicate one if an FCA-authorised firm (normally one with approver permission) has approved it under section 21 of FSMA, unless an exemption in the Financial Promotion Order applies. The FCA tells consumers "Professional advice on pensions is not free" and treats unexpected offers of a no-cost pension review as a likely scam.

Source: FCA pension scams page (updated 19 January 2026); FCA warning on risky investments and scams.

3. The data is recycled, aged or bought in

Signs: leads that are weeks or months old, prospects who don't remember enquiring, "data partners", survey or competition sign-ups repurposed as pension enquiries, or a supplier that can't say which advert a person clicked.

Recycled data is a commercial problem (people who asked about something else months ago rarely want a pension meeting) and a legal one, because consent doesn't travel with the data.

The rule: for email and text marketing, the ICO says consent for another organisation's marketing must name that organisation; generic consent to "selected partners" isn't enough, and consent given to one business isn't transferable to the next. For pension calls, regulation 21B needs consent to calls from the specific caller.

Source: ICO: using marketing lists; ICO: electronic mail marketing rules.

4. The consumer doesn't know which firm will contact them

If the person thinks they filled in a form on a comparison site, and then gets a call from your firm (and maybe two others), you start the relationship by explaining who you are and how you got their number. That's a poor first impression and a weak consent position.

It's also the root of the "sold to five advisers" complaint. A shared lead is almost always an unnamed-recipient lead.

The rule: the ICO's position is that consent to marketing from a third party needs that third party to be named, and generic "partners" wording doesn't do it. Separately, Consumer Duty's consumer understanding outcome expects people to be given the information they need to know who they're dealing with and why.

Source: ICO: using marketing lists; PRIN 2A.5 (consumer understanding).

5. Nobody checks the pension value

A dropdown clicked in five seconds tells you what the person thinks their pensions are worth, which may be right. But if the supplier never reconfirms it, and doesn't credit you when it turns out to be well out, the pot band on the lead is a claim you're paying for rather than something you can rely on.

This one isn't a legal rule so much as a warning that the rest of the process may be loose too. It's also where your Consumer Duty target market meets reality: if a third of prospects are outside it, your records will show it.

The rule: there's no specific rule on pot checks, and no FCA-prescribed method. This is a commercial standard. It links to Consumer Duty only because you're expected to serve your identified target market and monitor outcomes, so test whether the supplier's records give you enough to do that.

Source: PRIN 2A.3 (target market); PRIN 2A.9 (outcomes monitoring).

6. The introducer does fact-finds or risk questionnaires

A lead that arrives with a completed fact-find, an attitude-to-risk score or a note saying "client wants to move into X" is a lead where someone else has started the advice process. That's exactly what the FCA told advisers to look out for.

Facts and intent (pot band, age, what they want help with) are fine. Risk profiling, product preferences and "should you transfer" questions aren't.

The rule: the FCA's introducer alert lists, as warning signs, introducers who "provide input on fact find or attitude to risk questionnaires", who influence the final investment choice, and whose referrals mostly go into the same investment group. It tells advisers to maintain full ownership of the advisory process.

Source: FCA: advisers' responsibilities when accepting business from unauthorised introducers and lead generators (first published 1 August 2016, last updated 17 July 2026 with a link change).

7. The funnel pushes defined benefit transfers

"Find out what your final salary pension is worth", "access your pension early", "move your final salary pot". Some suppliers openly sell transfer interest as a feature. For most firms it's the highest-risk work in the market, and the FCA's introducer alert says its concerns have been particularly evident in advice on pension switches and transfers.

DB holders aren't a red flag. Plenty of people with £250k+ in defined contribution pots also have a DB pension they want to keep. A funnel built to find people who want to leave a DB scheme is.

The rule: firms must start by assuming a DB transfer isn't suitable (COBS 19.1.6G). Advice is legally required for safeguarded benefits over £30,000, from a firm with pension transfer permission. Under the 2021 transfer conditions regulations, trustees can block a transfer where there's a red flag such as unsolicited contact, an incentive to transfer or pressure to transfer quickly.

Source: COBS 19.1; Pension Schemes Act 2015, s48; TPR: dealing with transfer requests. Our full reasoning is in why we exclude DB transfers.

8. The introducer is paid more depending on what the client does

A bonus if the client transfers, a percentage of the money invested, a higher fee if the client goes into a particular product or platform. Each gives the introducer a reason to steer the conversation before you've had it.

Not every outcome-linked fee is banned. Share-of-fee arrangements exist outside DB work and can be run well. But the more the introducer earns from a particular outcome, the more your file needs to explain why that doesn't influence what the client is told.

The rule: for DB transfers, the FCA's guidance says an adviser cannot pay an introducer according to whether the advice results in a transfer, because it changes the adviser's net remuneration (the contingent charging ban has applied since 1 October 2020). More generally, the introducer alert lists introducers who "directly benefit from resulting investments" as a warning sign, and independent advice must not be tilted by payments linked to particular products or providers.

Source: FCA FG21/3; PS20/6; COBS 6.2B.

9. There's no consent record you can see

Ask for the consent record of one specific prospect. If the answer is "they ticked a box" with no wording, no timestamp and no advert, you have nothing to show the ICO, the FCA or the client if they later say they never agreed to hear from you.

A good record names the advert or page, the wording agreed to, the firm the person agreed to hear from, the date and time, and the contact methods covered.

The rule: under UK GDPR Article 7(1), where processing relies on consent the controller must be able to demonstrate that the person consented. The ICO's direct marketing guidance expects consent to be specific, recorded and kept up to date, including withdrawals.

Source: ICO guidance; UK GDPR Article 7.

10. It claims to be "FCA compliant" or regulated when it isn't

"FCA-compliant leads", "FCA regulated lead partner", an FCA logo in the footer. Most lead generators aren't authorised by the FCA (we aren't either), and that's allowed. What breaks the rules is implying that they are.

"Compliant" is the supplier's own opinion. The questions that matter are factual: is the firm on the FCA register, and if it isn't, which authorised firm approved its adverts under section 21?

The rule: GEN 1.2.2AR stops a firm, or anyone acting for it, implying that the FCA approves or endorses it; COBS 4.2.1R requires communications and promotions to be fair, clear and not misleading. Since 7 February 2024, an authorised firm needs the FCA's approver permission to approve promotions for unauthorised firms. The FCA issued 2,329 warnings about unauthorised or potentially scam firms in 2025.

Source: GEN 1.2; FCA: approving promotions for unauthorised persons; FCA Warning List; FCA register.

Red flag, rule and what to ask for

The same ten in one table, for an introducer file or a supplier call.

If you want this as part of a wider file, the full introducer due-diligence checklist, with target-market evidence and fee models, is in fair value assessment and Consumer Duty when you buy leads.

Why do these red flags matter more for pensions than for mortgages?

Because of history. Mortgage lead problems mostly cost brokers money. Pension lead problems have cost consumers their retirement savings, and advisers their permissions.

• Scams. Action Fraud recorded 519 pension fraud reports in 2024 with £17,567,249 lost, an average of £33,848 per victim (police figures, September 2025). The FCA's consumer warnings centre on the same two openings: the unexpected call and the offer of something for nothing.
• British Steel. The Public Accounts Committee found third parties introduced members to advisers in 30% of cases it looked at, including unregulated introducers. At least £106m has been offered in redress to 1,870 former members (FCA, March 2026).
• Enforcement follows the money. The EB Associates fine is a reminder that paying lead generators per referral doesn't move the legal risk off the firm making or instigating the calls.

Several of these flags are cheaper ways of generating volume, which is one reason they keep turning up when a lead business is paid by the lead.

What should you do if a supplier shows one of these?

1. Pause new introductions from that source until you have answers in writing.
2. Ask for the evidence in the table above, for specific named prospects, not a policy document.
3. Look back. Check recent introductions from the source: did any client mention a call they didn't ask for, or arrive with a completed fact-find or a product in mind?
4. Talk to your compliance function or network about whether anything needs recording, fixing or reporting.
5. Report where it's warranted. Unlawful calls and texts go to the ICO. Firms claiming a status they don't have can be reported to the FCA.

And if the answers are fine, write them down with the date. That's your due diligence.

How does InvestmentsBooked measure up against the list?

We'd expect you to put us through the same test. Here are our answers, so you can check them.

More detail on sourcing, promotions and data is on our lead quality page, with the show test and credit rules on pricing and the whole process on how it works. The four kinds of appointment we book are on appointment types.

Sources and checks. PECR: SI 2018/1396 (regulation 21B, in force 9 January 2019); ICO on the Data (Use and Access) Act 2025. ICO fines: CPS Advisory (September 2020), EB Associates (December 2021, via The Register). FCA: pension scams (updated 19 January 2026); introducer and lead generator alert; FG21/3; COBS 19.1, COBS 6.2B, COBS 4.2, GEN 1.2, PRIN 2A; 2025 warnings count. TPR transfer guidance. ICO marketing lists guidance. Fraud losses: Action Fraud 2024 via Suffolk Police. British Steel: Public Accounts Committee; FCA statement (26 March 2026). Figures checked 27 September 2026. This isn't legal advice. InvestmentsBooked is not authorised by the FCA and does not give financial advice.

FAQ