15-Month Pension Transfer Delays: What Business Owners and Directors Can Do?

A pension transfer should not normally take 15 months. Straightforward electronic pension transfers can be completed in days, yet some savers are still waiting months, and in exceptional cases more than a year, to move their retirement savings.

For company directors and business owners, the issue can become particularly complicated where a SIPP or Small Self-Administered Scheme (SSAS) is involved.

Scam-prevention checks, evidence requirements, disinvestment delays, manual administration and questions about the receiving scheme can all slow the process.

A delay does not automatically mean the pension has been lost or that a scam is taking place.

However, once a transfer drifts from weeks into months without a clear explanation, the pension holder should start documenting the delay, identify exactly where the transfer is stuck and consider making a formal complaint.

Why Are 15-Month Pension Transfer Delays in the News?

Consumer group Which? highlighted the case of John Wilson, whose attempt to consolidate three pension pots included one transfer that took 15 months.

The transfer initially became delayed because money had to be disinvested from his main fund. As the process continued, Wilson became increasingly concerned about what was happening to his pension.

His experience illustrates the difference between the typical pension transfer and the extreme cases hidden by industry averages.

Which? surveyed 1,360 members, but only 101 respondents had attempted a pension transfer during the previous three years.

Of that group, 10% said they eventually abandoned the process. In numerical terms, the widely reported “one in ten gave up” finding therefore represents roughly ten people rather than 136 people or 10% of the complete 1,360-person survey.

That does not make the experiences unimportant, but the sample size matters when interpreting the headline.

How Long Should a Pension Transfer Normally Take?

There is no single normal transfer time because pension transfers vary enormously in complexity.

Origo reported that straightforward transfers completed through its service averaged 10.2 days during 2025, with simple transfers accounting for nearly 90% of transfers measured in its index. Its latest Transfer Index now covers the 12 months to 30 June 2026.

The FCA’s review of life insurers provides another useful benchmark. More than three-quarters of the firms reviewed completed transfers requiring no additional checks within 10 days. It also found that digital transfers tended to move more quickly than manual processes.

That makes a 15-month wait an extreme outlier rather than a typical pension transfer experience.

The Average Pension Transfer Time Can Hide the Long Tail

Different datasets measure different parts of the market, so figures should not be treated as directly interchangeable.

Evidence	Finding	Important Limitation
Origo, 2025	Simple transfers averaged 10.2 days	Covers transfers through Origo and participating providers
PensionBee, 2024	Average transfer to PensionBee was 22.4 days	Only providers transferring pensions to PensionBee
10 fastest providers in PensionBee data	7.6-day average	Provider-specific sample
10 slowest providers in PensionBee data	44.2-day average	Provider-specific sample
Adviser survey	More than one in six advisers had experienced a transfer taking over one year	This means advisers experiencing such cases, not one in six transfers
Extreme adviser case	More than 1,000 days	An exceptional reported case rather than a market average
Which? survey	10% of transfer respondents gave up	Based on 101 people who had attempted transfers

PensionBee’s analysis illustrates the problem particularly clearly: its ten quickest providers averaged 7.6 days, while its ten slowest averaged 44.2 days.

Separately, a survey of more than 160 advice professionals found that more than one in six advisers had encountered at least one pension transfer lasting longer than a year, including one reported wait exceeding 1,000 days.

The important distinction is that this does not mean one in six pension transfers takes more than a year.

It means more than one in six surveyed advisers had encountered such a case.

Is There a Legal Six-Month Pension Transfer Deadline?

For occupational pension schemes, the statutory framework generally requires governing bodies to complete transfers within six months.

For defined contribution benefits, The Pensions Regulator says the period normally runs from the date of the transfer request. For defined benefit transfers, it normally runs from the guarantee date shown in the statement of entitlement.

Extensions are possible in limited circumstances, but an application for an extension must be made before the six-month period expires.

That makes six months an important escalation point.

It should not, however, be interpreted as a normal service standard. The regulator itself says most transfers should be completed well before the statutory deadline.

A provider taking four or five months should therefore not automatically be considered to be providing an efficient service simply because six months has not yet passed.

Why Can a Pension Transfer Take 15 Months?

A long transfer can have several causes, and identifying the exact cause is more useful than repeatedly asking a provider when the transfer will finish.

Disinvestment Can Delay the Transfer

Many pension transfers are completed as cash transfers.

That means investments in the existing pension need to be sold before the cash can be sent to the receiving provider.

Some investments are straightforward to sell. Others can involve third-party investment managers, less liquid holdings, trustee approvals or additional processing.

Origo specifically notes that transfers can take longer where providers are waiting for investment managers to disinvest funds or for trustees or other third parties to act.

Scam Checks Can Pause the Process

Since November 2021, pension trustees and managers have operated under transfer regulations designed to prevent pension scams.

Transfers can trigger red flags or amber flags.

A red flag can prevent the statutory transfer from proceeding.

An amber flag normally means additional safeguards must be completed, which can include obtaining pension scam guidance before the transfer continues.

MoneyHelper says providers do not necessarily have to disclose the precise reason an amber flag has been raised.

That can leave pension holders knowing that a safeguarding issue exists without receiving a detailed explanation of the provider’s underlying concern.

Missing or Inconsistent Information Can Create Repeated Delays

Transfer administration can also slow down because of differences involving names, addresses, employment details, signatures, identity verification, adviser details or receiving-scheme information.

Paper-based processes and transfers involving parties that do not use the same electronic transfer systems can introduce further friction.

High Transfer Volumes Can Affect Processing

Tax-year-end activity and periods of unusually high transfer demand can also place additional pressure on pension administrators.

That may explain a temporary delay, but it becomes less persuasive when a transfer remains unresolved for many months without a clear action plan.

Where Is the Pension Money During a Long Transfer?

There is no single answer, and a pension holder should not assume the money remains invested throughout the entire delay.

A cash pension transfer commonly involves selling investments and transferring the proceeds as cash. However, the exact point at which disinvestment takes place varies between schemes and transfers.

The pension holder should therefore ask the existing provider to confirm in writing:

Question	Why It Matters
Have the pension investments already been sold?	Establishes whether the pension remains exposed to investment markets
If they were sold, on what date?	Identifies when market exposure stopped
Where are the proceeds being held?	Clarifies the current status of the money
What exact action is preventing transfer to the new provider?	Separates disinvestment from later administrative delays
Is interest or investment return being applied while funds are waiting?	Helps establish possible financial loss
Has the receiving provider confirmed it is ready to accept the transfer?	Shows whether the blockage is with the old or new provider

This information becomes especially important where the market moves substantially during the delay.

Someone whose pension was disinvested months before a delayed transfer completes may have a very different potential loss from someone whose investments remained invested throughout the process.

Will the FCA’s New Rules Make Pension Transfers Faster?

That remains uncertain.

FCA consultation CP25/39 proposes additional information and comparison requirements before certain non-advised defined contribution pension transfers.

Under the proposal, a ceding firm would generally have 10 working days to supply requested information. The engaging firm would then have three working days to present the comparison after receiving the information or after the ten-day period expires.

The intention is to make sure consumers understand what they could lose or gain before moving their pension.

However, this creates an apparent tension: improving information before a transfer also introduces an additional procedural stage.

AJ Bell chief executive Michael Summersgill publicly described the proposals as “anti-consumer” and “anti-competitive”, arguing that they could create extra friction and delays. That is AJ Bell’s position rather than an established outcome of the proposed regulations.

The FCA consultation closed in February 2026. As of 21 September, its published page still says responses are being analysed and that a policy statement will follow.

Pensions Dashboards Will Not Be Public in October 2026

Another point requires clarification.

31 October 2026 is the final connection deadline for pension schemes and providers in scope. It is not the public launch date of the MoneyHelper Pensions Dashboard.

The Pensions Dashboards Programme currently expects the public MoneyHelper dashboard to become available during the 2027/28 financial year, meaning between April 2027 and March 2028.

Industry will receive at least six months’ notice of the eventual launch date.

That distinction matters because some earlier reporting suggested consumers would be using dashboards during 2026.

Why SSAS Transfers Matter Particularly to Business Owners

Small Self-Administered Schemes deserve particular attention because they are closely associated with business owners.

The DWP describes an SSAS as an occupational pension scheme typically established by company directors for themselves and key employees.

An SSAS can offer flexibility that conventional pensions do not, including investment in certain commercial property and, subject to strict rules, certain loans to a sponsoring employer.

That flexibility is one reason SSASs can be useful to legitimate businesses.

It is also why regulators are paying additional attention to how some SSAS transfers are being used.

The Proposed SSAS Employment-Link Red Flag

The DWP has proposed converting one particular situation into a red flag.

Where the member supplies the requested evidence but that evidence does not demonstrate the required employment link with the receiving occupational pension scheme, the proposed rules would allow the transfer to be stopped rather than merely triggering an amber flag.

For directors transferring into an SSAS, employment and company documentation could consequently become even more important if the proposal is implemented.

Company directors considering such a transfer should keep clear evidence covering the sponsoring employer, employment relationship, scheme documentation and the commercial rationale for the arrangement.

Can a Business Owner Be Compensated for a Delayed Pension Transfer?

Potentially, but compensation depends on what went wrong and whether an identifiable loss resulted.

The Pensions Ombudsman case involving Mr T and James Hay Partnership provides a significant example.

Mr T complained about unreasonable delays in transferring his pension. The Ombudsman upheld his complaint after finding that the delay caused him to lose an opportunity to invest following the EU referendum.

James Hay was ordered to pay £43,700 plus interest into his new pension plan.

Another James Hay determination required the provider to put a pension holder back into the financial position he would have been in if cash had transferred and been invested when it should have been, reimburse certain platform charges and pay £1,000 for distress and inconvenience.

A separate Financial Ombudsman case awarded £500 for the inconvenience caused by a pension-transfer-related delay even though the Ombudsman did not hold the business responsible for the much larger change in the transfer value.

These cases show why a complaint should distinguish between:

Financial loss — such as missed investment growth, unnecessary charges or another quantifiable financial consequence.

Distress and inconvenience — the disruption, uncertainty and additional work created by poor administration.

Compensation is not automatic simply because a transfer took a long time. Evidence connecting the provider’s avoidable error to the claimed loss can be crucial.

What Should Someone Do When a Pension Transfer Is Delayed?

A useful escalation timetable is:

Point in Transfer	Action
Week 4	Ask both providers for a written status update, identify the outstanding action and confirm whether investments remain invested or have been sold
Week 8	If there is still no credible timetable, consider making a formal written complaint and request an explanation for every period of inactivity
Week 12	Quantify potential loss, gather statements and correspondence, and review whether the complaint can already be referred to the relevant ombudsman
Week 26	For a transfer subject to the statutory six-month period, ask whether the deadline has expired and whether an extension was requested or granted
Beyond six months	Treat an unexplained continuing delay as a serious complaint matter and preserve evidence of financial impact

One important detail is that the eight-week complaint clock runs from the formal complaint, not automatically from the date the pension transfer started.

Is the Delay a Scam Check or Just Administration?

The distinction can often be narrowed down without guessing.

If the provider says pension safeguarding, suspicious circumstances or scam-prevention checks are responsible, the saver should ask whether the transfer is being considered under the red or amber flag framework, whether further evidence is required and whether MoneyHelper guidance must be completed.

If the provider instead refers to signatures, valuation work, identity verification, disinvestment, trustee approval, forms, adviser certificates or information from another provider, the issue is more likely to be administrative.

Where the provider repeatedly says only that the case is “being processed” without identifying the outstanding action, a formal complaint can force the firm to explain its position more precisely.

This does not mean scam checks should be bypassed.

MoneyHelper reports that more than £17.5 million was lost to pension scams in 2024, with an average reported loss of approximately £34,000 per victim.

The objective is therefore not to remove legitimate safeguards. It is to distinguish legitimate safeguarding from unnecessary delay.

Which Ombudsman Handles Pension Transfer Delay Complaints?

There is no perfectly simple dividing line.

The Financial Ombudsman Service (FOS) can deal with many complaints involving FCA-regulated pension providers, advisers and personal pensions.

The Pensions Ombudsman (TPO) deals extensively with pension administration disputes, including workplace and occupational schemes, and can also handle certain personal pension administration complaints.

The Financial Ombudsman itself acknowledges that there can be overlap between the two systems.

The provider’s final response should normally explain the appropriate escalation route.

Do Not Confuse the Complaint Time Limits

For FOS complaints, a consumer normally has six months from the date of a valid final response to refer the case to the Financial Ombudsman.

The Pensions Ombudsman uses a different standard.

TPO says complaints normally need to be submitted within three years of the event, or within three years of when the person knew or should reasonably have known about the issue. It has discretion to extend this in certain circumstances.

So saying that every pension complaint has a six-month Ombudsman deadline is incorrect.

Evidence Log for a Delayed Pension Transfer

Someone facing a serious delay should build a chronological evidence file rather than relying on memory.

Record	What to Capture
Transfer request	Submission date and reference number
Pension value	Value when transfer requested
Investments	Funds/assets held before transfer
Disinvestment	Date each investment was sold
Provider calls	Date, time, employee name and explanation
Emails and letters	Complete copies
Missing documents	What was requested and when supplied
Scam checks	Any reference to red or amber flags
MoneyHelper guidance	Appointment and completion date where applicable
Receiving provider	Confirmation it is ready to receive funds
Charges	Additional platform or administration costs
Investment performance	Evidence relevant to any claimed missed growth
Complaint	Formal complaint date
Final response	Date received and outcome

This evidence can be particularly important when arguing that an avoidable delay caused an investment loss.

Pension Transfer Delay Complaint Letter Template

A complaint should be specific about both the delay and the remedy being requested.

Formal Complaint – Delayed Pension Transfer

Dear Sir or Madam,

Please treat this correspondence as a formal complaint regarding the delay to my pension transfer.

I requested the transfer of my pension on [date] from [existing scheme/provider] to [receiving scheme/provider].

The transfer has now been outstanding for [number] weeks/months.

During this period I have contacted you on [dates], and I have been given the following explanations: [brief chronology].

Please confirm in writing:

1. The current stage of the transfer
2. The exact reason it has not completed
3. Whether any red or amber pension transfer flag has been applied
4. Whether any information or action is still required from me
5. Whether my investments have been disinvested and, if so, the date this occurred
6. Whether the transfer is currently awaiting action from your organisation, the receiving provider or another third party
7. The expected completion date and
8. Whether any statutory transfer deadline applies and, where relevant, whether an extension has been requested or granted.

I also ask you to investigate any financial loss caused by avoidable delays, including [additional charges/missed investment growth/other loss], together with the inconvenience caused by the prolonged administration.

Please provide your formal written response and explain how any proposed redress has been calculated.

Yours faithfully,

[Name]

The pension holder should adapt the wording to the facts rather than alleging a financial loss that cannot be evidenced.

What Business Owners and Directors Should Check Before an SSAS or SIPP Transfer

Directors can reduce avoidable friction by checking the receiving arrangement carefully before beginning the transfer.

For an SSAS, particular attention should be paid to the employment relationship with the sponsoring employer because that issue is at the centre of the DWP’s proposed new red flag.

For a SIPP, the investor should understand whether the transfer will be completed as cash or in specie, which investments can be accepted by the receiving provider and whether selling assets is required first.

In either case, the transfer should not be treated purely as an administrative switch.

Old pensions can contain guarantees, protected pension ages, safeguarded benefits or other valuable features that may be lost after transfer.

Pension Transfer Delays: The Key Difference Between Slow and Unreasonable

A transfer taking longer than ten days is not automatically unreasonable.

A complicated pension with safeguarded benefits, unusual assets or genuine scam concerns may reasonably take longer than a simple electronically transferred defined contribution pot.

The stronger warning sign is unexplained inactivity.

A provider that can show what checks are taking place, what information remains outstanding and what action is scheduled is in a very different position from one that repeatedly allows weeks to pass without identifiable progress.

That distinction becomes especially important once a delay reaches three months, six months or, as in the reported case, 15 months.

Frequently Asked Questions

Can a pension transfer really take 15 months?

Yes, exceptionally. Which? reported a case in which one transfer took 15 months, although straightforward transfers commonly complete far more quickly.

What is the average pension transfer time?

There is no universal average. Origo reported a 10.2-day average for simpler transfers during 2025, while other datasets show substantially wider differences between providers.

Is six months the legal maximum for a pension transfer?

Relevant occupational pension transfers are generally subject to a six-month statutory timeframe, although limited extensions can be available. Most straightforward transfers should complete significantly sooner.

Can someone complain before six months?

Yes. There is no requirement to wait six months before complaining about poor administration or an unexplained delay.

Does an amber flag mean the pension transfer is a scam?

No. An amber flag identifies circumstances requiring additional safeguarding. Legitimate transfers can trigger amber flags.

Does a red flag stop a pension transfer?

A red flag can prevent the statutory transfer from proceeding because it indicates a significant scam risk under the transfer regulations.

Does the provider have to explain an amber flag?

Not necessarily. MoneyHelper says providers do not have to tell pension holders the reason for an amber flag.

Can missed investment growth be compensated?

Potentially. Ombudsman decisions show that compensation can include financial loss linked to unreasonable delay, but the claimant normally needs evidence establishing what would probably have happened without the provider’s error.