COBS 19 — Pension transfers, conversions and opt-outs

Category: Compliance & AML · Reviewed by Simon Temme, Account Executive · Last reviewed June 2026

Definition

COBS 19 contains the FCA’s rules on pension transfers, conversions and opt-outs. Its most regulator-heavy area covers the transfer of safeguarded benefits — typically Defined Benefit (DB) pensions — to flexible benefit arrangements such as personal pensions. Following high-profile cases (notably British Steel from 2017 onwards), the FCA tightened the framework significantly through PS20/6.

Legal / Regulatory basis

FCA Handbook, COBS 19. Made under FSMA sections 137A and 138. The FCA’s policy direction is set out in PS20/6 (Pension transfer advice — contingent charging and other proposed changes) and earlier PS18/6.

How it works in practice

For DB-to-DC transfers above £30,000, advice from a pension transfer specialist is mandatory under the Pension Schemes Act 2015 s.48. The firm must perform an Appropriate Pension Transfer Analysis (APTA), apply the Transfer Value Comparator (TVC) and the starting assumption that a transfer is not suitable. Contingent charging is banned other than in specific carve-out cases. Abridged advice provides a triaging mechanism to identify obvious “no” cases before incurring full advice cost. Strict suitability rules apply with a clearly evidenced rationale required for any positive recommendation.

Common variations

For pure insurance brokers, COBS 19 has no application — but firms in the same group as a financial advice business will see it. For trustees offering investment risk-rated retirement options, separate COBS 9 considerations may apply.

Example

A member of a final salary scheme receiving a CETV (Cash Equivalent Transfer Value) of £600,000 considering a transfer must be given full advice by a pension transfer specialist within a firm holding the relevant permission. The starting position is that the transfer is unsuitable. The adviser must produce a Suitability Report.

See also

• COBS 9 — Suitability
• COBS — Conduct of Business Sourcebook
• PRIN 2A — The Consumer Duty

References

FCA Handbook, COBS 19. Financial Services and Markets Act 2000, sections 137A and 138. Pension Schemes Act 2015, section 48. FCA Policy Statement PS20/6 (Pension transfer advice).

Last reviewed

By Apex Insurance Brokers on 2026-06-11.

This entry is part of the Apex Insurance Wiki. Last reviewed by Apex Insurance Brokers on 2026-06-11. Apex Insurance Brokers Limited, FCA FRN 724952, Companies House 07014570. Not regulated advice — consult your broker on your specific position.