Lead quality & compliance

How we source, qualify and disclose every IFA lead

Written for you and for your compliance officer. Where prospects come from, what they're told, what we ask and don't ask, and exactly when you pay.

Published 27 Sep 2026 · 11 min read · Updated 27 Sep 2026
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How a prospect reaches your diary
  1. Sees one of our adverts, approved under section 21 before it runs.
  2. Answers the qualifier: facts and intent only, with hard exits for anyone who doesn't fit.
  3. Is told advice is paid for, that the adviser firm pays us, and that one firm will speak to them.
  4. Confirms their mobile with a one-time code and picks a time.
  5. Gets your firm name and FRN once you claim, with a link to the FCA register and the option to cancel.
  6. Meets you. You reconfirm the facts, and the published show test decides whether you're charged.

Where do the prospects come from?

From our own adverts. We run paid social and search campaigns aimed at people planning their retirement, and we control every step from the advert to the booking: the creative, the landing page, the qualifier, the calendar and the messages that follow.

  • No bought data. No purchased lists, co-registration or data brokers.
  • No unsolicited calls. We don't make unsolicited pension marketing calls. The prospect contacts us through the form; reminders are service messages about the booking they made.
  • No "free review" hooks. The FCA warns consumers that professional pension advice is not free, and that a call out of the blue about a pension is a warning sign (FCA, pension scams). Our adverts say advice is paid for.
  • No resale. One appointment goes to one firm.
  • No provider money. The adviser firm pays us a flat fee per show. We take nothing from pension, platform or investment providers.

On calls: since January 2019, pension marketing calls can only be made by FCA-authorised firms or scheme trustees and managers, and only with consent or an existing relationship (PECR regulation 21B, ICO guidance). We're not authorised, so we stay well clear: we don't phone prospects at all.

How are the adverts approved?

An advert that invites someone to get advice on their pension is a financial promotion. An unauthorised business like ours can only communicate one if an authorised firm has approved it, or an exemption applies (FSMA section 21). The introductions exemption doesn't fit us, because it requires that the introducer is paid only by the consumer, and we're paid by the adviser (PERG 8.12).

So: every consumer advert is approved by an FCA-authorised firm under section 21 of FSMA before it runs. Since 7 February 2024, a firm approving promotions for an unauthorised business needs the FCA's approver permission, and has to keep monitoring what it approved (FCA). Social media adverts also have to stand on their own as fair, clear and not misleading (FCA FG24/1).

We don't name the approver on this site. The approver's details and examples of approved adverts are in the due-diligence pack you get during onboarding.

  • Advice is described as paid for, never free
  • No promises about returns, tax savings or outcomes
  • No FCA logo, and no suggestion the FCA endorses us
  • No mention of transferring a final salary pension
  • Clear that the prospect will speak to a regulated adviser firm, not to us

What is the prospect told before the call?

Three things, before they book or before the call, so nobody is surprised when you ring:

  • That advice is paid for. The qualifier says regulated advisers charge for advice, that the first conversation costs them nothing, and that the adviser will explain fees before any work starts. They have to confirm they understand.
  • That the adviser firm pays InvestmentsBooked for the introduction. We're open about how we're paid.
  • Which firm they'll speak to. 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. The confirmation names your firm, your adviser and your FRN, links to your FCA register entry, and lets them cancel.

Their details go to one firm and no further. The ICO expects people to know exactly who will receive their data, so we never pass a prospect to a second firm, sell them on, or share them with anyone else for marketing (ICO lead-generation guidance). The exact consent wording and when each step happens are in the due-diligence pack.

What do we ask, and what don't we ask?

The prospect answers one question per screen before they can see a calendar. Every answer lands in your pre-meeting brief. We label each field by how far to trust it: most are the client's own answers, a few we check, and consent is a timestamped record.

What we askDetailHow far to trust it
Pension value band£250k–£500k, £500k–£1m or £1m–£3m, all defined contribution pots combined. Plus an approximate total if they know it.Self-declared
Pension typesWorkplace, old workplace, personal, SIPP, final salary not yet paid, final salary in payment, annuity.Self-declared
Number of pots Self-declared
AgeFrom year of birth.Self-declared
Retirement stage5+ years away, 2 to 5 years, within 2 years, recently retired, retired 2+ years.Self-declared
EmploymentEmployed, self-employed, company director, retired, not working.Self-declared
Pensions already accessed?Flags tax-free cash taken and whether the money purchase annual allowance may apply.Self-declared
Help wanted (up to 3)Retirement income plan, combining pots, tax-free cash, drawdown vs annuity, inheritance tax and passing pensions on, investment and charges review, early retirement.Self-declared
Other investable assetsA band covering ISAs, general investment accounts and cash.Self-declared
Home and propertyOwns outright, has a mortgage or rents, and any other property.Self-declared
Current adviserNone, has one but wants a second opinion, or has one and is unhappy.Self-declared
Advice feesThey confirm they understand regulated advice is paid for. "Free guidance only" ends the booking.Recorded answer
TimescaleWithin 3 months, 3 to 6 months, 6 to 12 months.Self-declared
Partner joining? Self-declared
Meeting type and postcode districtVideo, phone or face to face.Self-declared
Mobile and emailMobile confirmed with a one-time code; email checked for deliverability.Checked
Booking requestThe 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.Recorded answer

Hard exits. The booking ends, with a signpost to MoneyHelper or Pension Wise, if the prospect has pensions under £250k, lives outside the UK, wants free guidance only, or wants to transfer a final salary pension (see DB transfers).

What we deliberately don't ask:

  • Attitude to risk or capacity for loss
  • Whether they should transfer, consolidate or buy an annuity
  • Which provider, fund or product they want
  • Income and expenditure detail
  • Health details (the free-text box asks them not to include any)

This is on purpose. The FCA lists introducers completing fact-finds or attitude-to-risk questionnaires, and consumers arriving with predetermined investment choices, among the red flags in a pension lead source for advisers taking business from unauthorised introducers. It expects you to "maintain full and complete ownership of the advisory process" (FCA, updated July 2026). We collect facts and intent, so the advice starts with you.

Why £250k? The floor came from IFA research, not from a guess. Reported average minimum investable assets sit around £168,000 (Dynamic Planner's 2026 adviser survey), Octopus Money's 2024 research found £214,000, and NextWealth's 2026 benchmarks reported an average minimum initial fee of £1,949. A £250k floor clears those averages, but your minimum may be higher, so you can set yours at £500k or £1m instead. If you set a higher minimum (£500k or £1m) and the prospect confirms pensions below the band you selected, the show is credited, even if they hold £250k or more. An average can't tell you whether a particular prospect fits your firm. The brief and the call can.

Why self-declared? Because asking for pension statements before a first meeting stops good prospects booking, and we'd be handling documents we don't need. So the band is the client's own estimate, you reconfirm it on the call, and if it comes in under £250k (or under the minimum you set), you're credited.

What counts as a qualified show?

The £500 is charged only when all of these are true:

  1. They turned up. They joined the video call, answered the phone or arrived for the meeting within 15 minutes of the booked (or rebooked) start.
  2. You talked about their retirement for at least 10 minutes. A genuine conversation about their pensions and plans, not a two-minute "I'm not interested".
  3. It was the person who booked. Their partner joining as well is welcome. A partner on their own is rebooked, not charged.
  4. They confirm defined contribution pensions at or above the minimum band you selected. That's £250,000 or more, or £500k+ or £1m+ if you set a higher minimum. Their band is self-declared, so you reconfirm it on the call. A lower band than they picked still counts if it's at or above your minimum. Below your minimum is credited, even if they hold £250k or more.
  5. They live in the UK.
  6. They're not already your client or a live prospect. You'd need a record in your CRM dated before the booking.
  7. They want regulated advice and accept that advice is paid for. They can still question your level of fee. What fails the test is someone who wants free guidance only, or won't pay any fee for advice.
  8. They can be advised. They're 18 or over, and they aren't only after something you've switched off (a DB transfer, for example). Whether you can take them on is your judgement as the authorised firm; we don't pre-judge it and our qualifier doesn't assess it. If you decide on the call that you can't advise them (for example, you have concerns about their capacity to make the decision), flag it within 72 hours with the reason and what you observed, and we review it like any other disqualification.

No-shows, cancellations without a rebook, invalid contact details, technical failures, a partner on their own and anyone who fails the test are credited back. Not becoming a client, wanting time to think, or objecting to your level of fee still counts as a show. Side by side:

Credited back: you don't pay
  • No-show. They don't join, or join more than 15 minutes late.
  • Cancellation not rebooked. They cancel, even at the last minute, and don't rebook with you within 7 days.
  • Below your selected band. You set a minimum of £500k or £1m, and they confirm pensions below it, even if they hold £250k or more.
  • Invalid contact details. The mobile or email doesn't work.
  • Technical failure. The call can't happen because the line or video fails. We rebook, and nothing is charged until the call takes place.
  • Partner turns up alone. We rebook with the person who booked.
  • You missed the call. We rebook, and you're charged only if the rebooked call shows.
  • Disqualified. They fail the show test: pensions under £250k (or under the minimum you selected), not UK resident, already your client, free guidance only, won't pay any fee, or you can't advise them. Flag it within 72 hours with a reason.
Still a show: you pay £500
  • They don't become a client. You pay for a qualified conversation, not a sale.
  • They want time to think.
  • They object to your level of fee. As long as they accept that advice is paid for.
  • They already have an adviser but took the call for a second opinion.
  • Their pensions sit at the low end of the band, or in a lower band than they chose, but still at or above the minimum you selected.
  • They want their partner at a second meeting.

And if you think we've got an outcome wrong:

  1. Flag it within 72 hours of the booked start, with a reason and a line of detail.
  2. We check it against the booking record, the prospect's answers and a short feedback email we send them. We don't phone them. Send anything that supports your case: your call notes, your CRM record, or a recording if you made one with the prospect's agreement.
  3. You get a decision within 2 business days. If it's a disqualification, the credit goes back to your balance with a fresh 6-month expiry.
  4. Not happy with the decision? Ask us to review it again, and tell us what we missed.

The remedy is a credit back to your balance, not cash. The same rules are on the pricing page.

How does this fit Consumer Duty?

You can't hand your Consumer Duty responsibilities to an introducer, and we don't claim to take them. What we can do is make the introduction easy to defend:

  • Target market. You set the pot band, advice areas, meeting types and whether you see DB holders. The brief records how each prospect matched those filters.
  • Informed consumers. They know advice is paid for, that you pay us, and who they're speaking to, before the call.
  • A flat fee per show, whatever the outcome. We're paid the same whether the prospect invests nothing or everything, transfers or doesn't. Nothing in our model rewards pushing a product, a transfer or a bigger investment.
  • Outcome evidence. Each prospect gets a post-call feedback email (did the call happen, how was it), and we share the answers with you as evidence of how prospects experienced the first meeting.
  • Vulnerability. We don't collect health information. The free-text box asks prospects not to include any, and spotting vulnerability stays with you on the call.

Pricing per show also removes a conflict we'd have if we charged a share of fees or assets: our income doesn't depend on what the prospect is advised to do.

What does your introducer due diligence need from us?

The FCA expects advice firms to carry out "robust due diligence on the introducers you transact with" and to check introductions "have been sourced legitimately", and it notes the problem has been most visible in pension switching and transfers (FCA). So during onboarding you get our introducer due-diligence pack:

SourcesWhich channels the prospects came from, and what we don't use.
Example approved advertsWith the approver's details.
Qualifier scriptEvery question and answer option, word for word, including the hard exits.
Consent wordingWhat the prospect agreed to, and when.
Data-sharing termsWho controls what, retention and breach handling.
Complaints processHow complaints about our service are handled, and where complaints about advice go.

If your compliance team or network needs something that isn't in it, ask us.

Who controls the data?

InvestmentsBooked is the controller of the prospect's data while we run the booking. When you claim an appointment, your firm becomes an independent controller of the details passed to you, for the purpose the prospect agreed to: a conversation about their retirement with your firm.

  • You contact the prospect only about the booked appointment and any advice relationship that follows.
  • You don't resell the data or add it to marketing lists without your own lawful basis.
  • We don't pass the prospect to anyone else.
  • We keep booking records for disputes and complaints for a set period, set out in our privacy notice.

The data-sharing terms sit in the adviser terms you sign, and a copy is in the due-diligence pack.

Why are DB transfer seekers excluded?

Because it's the highest-risk corner of retirement advice, and most firms can't or won't do it. Advice is legally required before transferring safeguarded benefits worth more than £30,000, it has to come from or be checked by a pension transfer specialist, and the FCA tells firms to start from the assumption that a transfer won't be suitable (COBS 19.1). The British Steel scheme alone led to over £100m of redress offers to former members (FCA), and many professional indemnity policies exclude or limit DB transfer work.

So our rule is simple:

  • Prospects who say they want to transfer a final salary pension are screened out by default.
  • People who hold a DB pension and aren't transferring are included, and the brief says so. You can switch them off.
  • If transfer intent comes up on the call and you don't do that work, it's a disqualification and the show is credited.
  • A separate DB transfer stream is available only to firms whose pension transfer permission we have verified, by arrangement, at the same fee whether or not a transfer happens.

The full reasoning is in why we exclude DB transfer seekers.

Next steps: see pricing, the step-by-step on how it works, or the appointment types, from pension consolidation to £1m+ pots. We also wrote up what Consumer Duty means when you buy leads.

Sources, checked 27 September 2026. FCA, advisers' responsibilities when accepting business from unauthorised introducers (updated 17 July 2026); FCA, approving financial promotions for unauthorised persons; PERG 8.12; FG24/1; ICO, telephone marketing; COBS 19.1; FCA, BSPS redress. Minimums: Dynamic Planner Advice 2026 report (reported); Octopus Money (2024); NextWealth via Money Marketing (reported). This page is our summary, not legal advice.

FAQ

Is InvestmentsBooked regulated by the FCA?
No. InvestmentsBooked is not authorised by the FCA and does not give financial advice. Our consumer adverts are approved by an FCA-authorised firm under section 21 of FSMA before they run, and we introduce people only to FCA-authorised independent advice firms.
Will this pass my compliance team's introducer due diligence?
That's their call, and we'll make it easy. During onboarding we give you our introducer due-diligence pack: where prospects come from, example approved adverts, the qualifier script, consent wording, data-sharing terms and our complaints process.
Do prospects know they'll pay for advice?
Yes. Before they can book, they're told regulated advice is paid for and must confirm they understand. "Free guidance only" ends the booking with a pointer to MoneyHelper and Pension Wise. They're also told the adviser firm pays InvestmentsBooked for the introduction.
Has anyone done a fact-find or suggested a product?
No. We record facts and what the prospect wants help with. We don't ask attitude to risk, suggest products or providers, or say whether they should transfer or consolidate. The advice process is yours from the first minute.
Can an appointed representative buy appointments?
Yes, if you're independent and your principal's introducer policy allows it. We check both you and your principal on the FCA register when you apply.
What if the prospect has already spoken to other advisers?
We can't stop anyone contacting other firms on their own, and we don't pretend to. What we control: we introduce them to your firm only, and we don't sell contact lists or pass their details to any other firm. The brief tells you whether they already have an adviser.