Pension transfer leads: why we exclude DB transfer seekers by default
The rules on DB transfer advice and introducer payments, what British Steel showed, who with a final salary pension we do book, and the opt-in available by arrangement to firms with the permission.
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This explains a commercial and compliance decision we've made, with the rules behind it. It isn't legal, compliance or financial advice. Rules are quoted as they stood on 27 September 2026. InvestmentsBooked is not authorised by the FCA and does not give financial advice.
People search for "pension transfer leads" and find suppliers happy to sell them, sometimes with DB transfer interest listed as a feature. We could do the same. DB transfer enquiries are some of the easiest pension enquiries to generate, because the transfer values people read about in the press are large and the pitch writes itself.
We've chosen not to, at least not by default. This post explains why, which people with a DB pension we do book, and what we offer firms that hold the permission and want the work.
What are pension transfer leads?
The phrase covers two very different things, and lead sellers don't always separate them.
- Defined contribution transfers. Moving money between DC pots: consolidating old workplace pensions into a SIPP, or switching provider. It's ordinary advice work for any firm with investment permissions, and it's a big part of what our appointments are about (see pension leads).
- Defined benefit transfers. Giving up a guaranteed final salary income in exchange for a cash equivalent transfer value moved into a DC arrangement. This is specialist, heavily regulated advice with a long complaints tail.
When this post says "DB transfer seekers", it means the second group: people who want to leave a DB scheme. It doesn't mean everyone who has a DB pension.
Demand is also smaller than it was. The FCA's retirement income market data for 2025/26, published on 24 September 2026, shows DB to DC transfers continued to fall, to 6,083, from 6,418 the year before.
Why do we exclude DB transfer seekers by default?
Four reasons, in order of weight.
- Many of the firms we sell to can't advise on them. We sell to independent firms, and many don't hold pension transfer permission (the FCA counted 3,042 holders in 2018 and 1,965 by March 2020). A DB transfer seeker booked with a firm without it is a wasted meeting for both sides.
- The regulator's starting point is "don't". Advice starts from the assumption that a transfer is unsuitable. A funnel built to find people who want to transfer is working against that assumption from the first advert.
- The introducer's position is fragile. The FCA's concerns about unauthorised introducers have been "particularly evident" in pension transfers, and the rules on paying introducers for DB work are tight.
- The downside lands on the adviser for years. PI exclusions, ombudsman awards and redress schemes all attach to the firm that gave the advice, not to whoever generated the lead.
Each of those is set out with its source below.
What are the rules on DB transfer advice?
A summary for context. Firms that do this work will know it in far more detail.
| Rule | What it says | Source |
|---|---|---|
| Starting assumption | Firms should start by assuming a transfer, conversion or opt-out won't be suitable, and only consider it suitable where they can clearly show it's in the client's best interests | COBS 19.1.6G |
| Advice is compulsory above £30,000 | Trustees must check the member took appropriate independent advice before transferring safeguarded benefits worth more than £30,000 | Pension Schemes Act 2015, s48 |
| Permission and specialist | The advising firm needs pension transfer permission; advice is given or checked by a pension transfer specialist | FCA expectations |
| Contingent charging ban | From 1 October 2020, the same charge for full advice whether or not the client transfers. Carve-outs for serious ill health and serious financial difficulty | PS20/6 |
| Abridged advice | Can only conclude "don't transfer" or "you need full advice"; can't recommend a transfer | COBS 19.1A |
| Transfer red flags | Trustees can refuse a statutory transfer where there's a red flag, including unsolicited contact, an incentive to transfer, or pressure to transfer | TPR guidance on the 2021 regulations |
The FCA's evaluation of the contingent charging ban (EP25/1, 30 January 2025) estimated it reduced the number of firms giving DB transfer advice by 129 in its first year and by 195 by September 2022. It found fewer transfers, but the expected fall in fees for clients advised to transfer didn't happen. For a lead business, the practical point is that fewer firms can take the meeting.
What do the rules say about paying introducers for DB work?
This is the point that settled it for us.
The FCA's guidance on advising on pension transfers, FG21/3, says an adviser can't pay an introducer according to whether the advice results in a transfer, because that changes the adviser's net remuneration and would undo the contingent charging ban by the back door. So a "pay per transfer" lead deal is out. So is anything that works the same way in practice, like a large bonus on completed cases.
On top of that, the FCA's alert to advisers accepting business from unauthorised introducers says its concerns have been particularly evident in pension switching and transfers. Its warning signs include introducers who help with fact-finds or risk questionnaires, influence the choice, or benefit from the result.
A flat fee for an attended meeting doesn't depend on whether a transfer happens, so it avoids that specific problem. It isn't certified as safe by anyone, and the whole arrangement would still need assessing. But even with the fee sorted, the funnel still has to avoid the "release the cash in your final salary pension" style of advert that attracts people already convinced they should transfer. That's harder to do well than it sounds, and it's why the default is off.
What does DB transfer risk look like for a firm?
It's worth reminding ourselves how much the market has shrunk and why.
- Permissions. The FCA counted 3,042 firms with DB transfer permission in its October 2018 data request and 1,965 by 31 March 2020 (FCA market data). In its June 2020 update it said 745 firms had changed their pension transfer permissions following its work, and 55 had stopped after it found their PI cover was inadequate (FCA DB transfers update).
- Professional indemnity. The FCA told firms to stop DB transfer advice, including cases in the pipeline, if they didn't have adequate PI cover, and said cover shouldn't exclude DB transfers or use sub-limits and excesses that defeat the minimum. That instruction is the one that took 55 firms out of DB advice in 2020.
- Ombudsman awards. For complaints referred to the Financial Ombudsman from 1 April 2026 about acts on or after 1 April 2019, the maximum award is £455,000 (Financial Ombudsman). DB complaints can arrive many years after the advice.
- The levy. When firms fail, the bill moves to everyone else. In 2025/26 the FSCS recorded £125.152m of compensation costs in the class that covers investment, pension and SIPP advice (FSCS annual report). That's a broad category, not DB alone, but it shows who pays when advice firms fail.
None of this means DB transfer advice is wrong. For some clients, advised properly, a transfer is the right answer. It means the work belongs with firms that are set up for it, and not in a general appointment stream.
What did British Steel show about introducers?
British Steel is the case every compliance officer thinks of first, and with reason. The FCA's statement of 26 March 2026 says at least £106m has been offered to 1,870 former British Steel Pension Scheme members across the FCA, the Financial Ombudsman and the FSCS (FCA). Within that, the FCA's own redress scheme offered £8.7m to 360 members, and by July 2024 15 individuals had been banned from financial services or specific roles (FCA, July 2024).
The introducer part is the one that matters for a business like ours. The Public Accounts Committee reported that in the cases it examined, third parties introduced members to advisers in 30% of cases, including unregulated introducers. Some of those introducers were approaching steelworkers directly and passing names to advisers.
We don't give pension advice, so our test is a simple one. Would we be comfortable with a saver being booked with a firm through a funnel that found them by advertising transfers, however good the adviser? We wouldn't, and that's the test we've applied here.
DB holders vs transfer seekers: who do we book?
Excluding transfer seekers doesn't mean excluding everyone with a final salary pension. Plenty of people approaching retirement have a DB pension and sizeable DC pots, and the DB income is exactly what an adviser needs to know about when planning drawdown or an annuity around it.
Our booking form asks for the value of DC pensions separately, with a note not to include final salary pensions in that figure. It then asks which types of pension the person has, and anyone who ticks a DB pension is asked whether they want to keep it or transfer it.
| Who | What happens | What you see |
|---|---|---|
| Has £250k+ in DC pensions and a DB pension they want to keep | Booked as normal (unless your firm has switched DB holders off) | DB pension listed on the brief as context for income planning |
| Has £250k+ in DC pensions and a DB pension already paying out | Booked as normal | DB in payment listed on the brief |
| Wants to transfer out of a DB scheme | Not booked by default. Signposted to MoneyHelper's guidance on DB transfers instead | Nothing: they don't reach your diary |
| DB pension only, under £250k in DC | Not booked (outside the £250k–£3m DC band) | Nothing |
Because the £250k floor applies to defined contribution money only, a large DB pension can't be used to get someone over the line. That keeps the appointment about the work most independent firms can do.
And if someone in a booked meeting turns out to be mainly interested in transferring their DB pension, and your firm doesn't do that work, the show test treats it as a disqualification: they're looking for something your firm has opted out of, so the credit comes back (flag it within 72 hours with the reason). The full show test is on the pricing page.
What about firms with pension transfer permission?
Some firms do this work well, hold the permission and the cover, and would welcome properly sourced enquiries. We don't want to pretend DB advice doesn't need to happen: people with safeguarded benefits over £30,000 who are thinking about a transfer are legally required to take advice, and it's better they get it from a specialist than from nobody.
So there's a separate opt-in stream, available by arrangement to firms with verified pension transfer permission. It's off by default and set up firm by firm. The rules we apply:
- Permission checked on the FCA register before a firm can switch it on, and rechecked while it's on.
- A named pension transfer specialist at the firm.
- Consumer framing: advice on whether to keep a final salary pension. No "release the cash" or "access your pension early" hooks, and no transfer values in adverts.
- The same fee whatever the outcome. A meeting that ends in "keep it" is charged exactly like one that ends in a transfer recommendation, consistent with FG21/3.
- Its own price, agreed in writing before the stream is switched on, which may differ from the £500 DC appointment, because the economics differ (many outcomes will be "don't transfer", with abridged or full advice priced by the firm).
If you hold the permission and want DB appointments, say so on your application or send us a message. It's arranged with specialist firms one at a time rather than opened to everyone.
How are mixed and unclear DB cases handled?
The clean cases are easy. The ones that need thought:
- "Not sure yet." Someone who holds a DB pension and hasn't decided whether to keep it isn't asking for transfer advice, but may raise it. If your firm doesn't do DB work, say so early in the meeting and signpost. If the meeting still covers their DC pensions and retirement income, it's a show like any other.
- A couple where one partner has the DB pension. The brief records what the person booking told us. Partner assets are for your fact-find, not ours.
- DB in payment. Someone already drawing a DB pension has no transfer decision to make. The income sits underneath any drawdown or annuity plan, and it's shown on the brief.
For a firm with the permission that wants the opt-in, the evidence we ask for is your firm reference number (so we can check the permission on the FCA register), the name of your pension transfer specialist, and confirmation that your own charging meets the contingent charging rules. We also agree the consumer wording with you before anything runs.
Why does saying no matter to a compliance officer?
Because it shows where the lines are. A supplier that turns away an easy, high-demand segment is telling you something checkable about the rest of its funnel, and compliance officers will ask how we source and qualify prospects. It's also the better outcome for the consumer: someone who wants a transfer, booked with a firm that can't advise on it, has wasted an hour. Pointing them to MoneyHelper's DB transfer guidance at the start is better for them.
For everyone else, the standard applies: £250k–£3m in DC pensions, self-declared and reconfirmed on the call, no unsolicited pension marketing calls, and £500 per qualified show (no VAT added), with no-shows credited back. The prospect asks us to book them with one FCA-authorised independent firm. We share their answers with that one firm only, and we tell them the firm's name and FRN as soon as it claims the booking, before the call. Minimum purchase is 10 appointments (£5,000) and credits are valid for 6 months. Credits that come back to your balance (a no-show, a cancellation that isn't rebooked, a disqualification or any other credit) come back with a fresh 6-month expiry. The DC appointments we book are on appointment types. More on how prospects are sourced is on our lead quality page, and the full process is on how it works. If you're building your introducer file, the checklist is in fair value assessment and Consumer Duty when you buy leads, and the warning signs in any supplier are in pension lead red flags.
Sources and checks. FCA Handbook: COBS 19.1 and COBS 19.1A. Legislation: Pension Schemes Act 2015, s48. FCA: PS20/6; FG21/3; EP25/1 (30 January 2025); DB transfers update (June 2020); DB market data 2018–2020; retirement income market data 2025/26 (24 September 2026); British Steel statements (July 2024, March 2026); introducer alert. Public Accounts Committee. Financial Ombudsman award limits. FSCS annual report 2025/26. TPR transfer guidance. Figures checked 27 September 2026. This isn't legal advice. InvestmentsBooked is not authorised by the FCA and does not give financial advice.