DWP opens consultation on amending pension transfer scam protections

The Department for Work and Pensions (DWP) opened a consultation on 9 June 2026 on proposed amendments to the Occupational and Personal Pension Schemes (Conditions for Transfers) Regulations 2021¹. The consultation runs until 21 July 2026, closing at 11:59pm, and applies to England, Scotland and Wales¹. Occupational pensions are a devolved matter for Northern Ireland, and DWP says it is working with the Department for Communities there¹.

The 2021 regulations came into force in November 2021 and set conditions that must be met before a statutory pension transfer can proceed, using red flags that let trustees block a transfer and amber flags that require the member to take guidance from the Money and Pensions Service (MaPS)¹. DWP estimates the regulations have prevented around 2,000 transfers potentially involving fraud¹. Its 2023 review collected data across four calendar quarters covering approximately 290,000 completed transfers, drawing on over 20 pension schemes, administrators and industry bodies, 11 of which provided detailed data, together representing more than 10 million members¹.

The main new measure targets Small Self-Administered Schemes (SSASs), occupational schemes typically set up by company directors for themselves and key employees¹. There are around 60,000 SSAS savers across 21,000 schemes, with an average of over 100 transfers into SSASs a year; DWP says up to 1 in 10 of these could involve fraud, which it describes as likely a significant underestimate because of under-reporting¹. The proposed change would amend regulation 8(5) so that a red flag applies where trustees determine that evidence provided by the member does not demonstrate an employment link with the receiving scheme¹.

Other proposed amendments address operational issues from the 2023 review¹:

The review found waiting times for MaPS safeguarding appointments rose from 2 to 6 weeks during the 18-month review period, with many members attending appointments where there was no suspicion of a scam³. As of 2025, over a third of safeguarding appointments were triggered solely by the overseas investment amber flag¹. On fraud losses, DWP cites Report Fraud data showing the average financial loss in 2024 to 2025 was £18,400, rising to £38,400 per victim where an investment was the primary vehicle for pension fraud, as is commonly seen in SSAS case studies¹.

Why it matters for households

The rules govern when a pension transfer can be stopped or delayed, so the proposals affect anyone moving a pot between schemes. The SSAS measure would give trustees a specific ground to refuse a transfer into a SSAS where no employment link is shown, which applies to the small number of savers using those schemes¹. The other changes are procedural: broadening the First Condition could reduce blocking of transfers where trustees have no scam concern, and the MaPS exemption would remove a repeat appointment for people consolidating several pots within 12 months¹. The removal of the overseas investment amber flag would mean that indicator no longer triggers a mandatory guidance appointment, though DWP states the provision remains an effective scams indicator¹. The consultation document notes that later this year the wider programme will look at modernising transfer processes and helping savers make informed decisions¹. DWP has not reported the outcome of the consultation.

What happens next

The consultation closes at 11:59pm on 21 July 2026². DWP says it will aim to publish the government response on GOV.UK¹. The draft regulations are cited as the Occupational and Personal Pension Schemes (Conditions for Transfers) (Amendment) Regulations 2026¹. No commencement date for the amendments has been reported.