In brief

Following changes brought in by the Pension Schemes Act 2021 and a consultation held earlier in the year, the DWP has published the final regulations which introduce additional conditions designed to prevent pension scheme members falling victim to scam transfers. The proposals give trustees powers to reject transfer requests in certain circumstances. In addition, members will be required to take specific guidance from the Money and Pensions Service (MaPS) where there is a prescribed “amber flag” (e.g. if the proposed investment structures in the receiving scheme are complex). The Pensions Regulator has also published guidance to assist trustees and administrators in dealing with transfer requests in light of the changes.

Trustees should urgently liaise with their administrators to check that their transfer systems can be modified to accommodate the new statutory requirements by 30 November. In particular, trustees should consider requesting information on how the administrators intend to assess the more subjective elements of the new conditions, such as what would constitute a “high risk” or “unorthodox” investment in a receiving scheme.


  1. Background
  2. What are the new measures being introduced from 30 November?
  3. What is a “red flag”?
  4. What is an “amber flag”?
  5. What are the “employment link” and the “residency link”?
  6. Further Pensions Regulator guidance
  7. Key takeaways and action points


In the Pension Schemes Act 2021 (PSA21), the Government…

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