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Britain’s financial watchdog wants pension providers to clean up their act on older, closed products — and it’s not asking nicely anymore. The Financial Conduct Authority found that legacy pension products deliver worse value than newer alternatives, and it’s pushing the industry hard to fix that.
The FCA’s review zeroed in on unit-linked non-workplace pension products that are closed to new savers. These are the old books — products nobody’s selling anymore but that still hold money for existing customers. The problems aren’t subtle. Complex fee structures, outdated product designs, and poor data management all pile up to leave some pension holders with meaningfully worse outcomes than people in newer products. It’s basically a two-tier system, and the regulator’s had enough of it.
Not all firms are dragging their feet.
Some providers are already capping or cutting charges, simplifying product structures, and actively moving customers into better-value alternatives. The FCA wants that to become the norm, not the exception. Those firms doing the right thing are setting a benchmark, per the regulator’s own framing — the implication being that everyone else needs to catch up fast.
Charlotte Clark’s Warning to the Industry
Charlotte Clark, the FCA’s director of cross-cutting policy and strategy, was direct: consumers with older products shouldn’t get left behind. That’s pretty much the core message. People who bought pension products years ago, often with less transparency and fewer choices available to them, shouldn’t be penalized just because their product is old and the provider has since moved on to shinier offerings.
Clark tied the legacy product push to broader FCA reform work — pensions dashboards and targeted support measures are both in the mix. Pensions dashboards, which aim to give savers a consolidated view of all their pension pots in one place, have been a long time coming across the UK industry. Targeted support is a separate strand of reform designed to help consumers make better decisions without necessarily needing full financial advice. Both of those, combined with the legacy product cleanup, seem to be part of a coordinated push to modernize the entire pensions landscape rather than just patch individual problems.
The FCA also said it’s actively engaging with firms to understand the barriers they face. Outdated systems are one issue. Organizational resistance to change is another. The regulator’s tone is firm but it’s not purely punitive — there’s an acknowledgment that some of these fixes are genuinely hard to implement, especially in legacy books where the underlying infrastructure is old and data quality is patchy.
SIPP Consultation Still Open
Separately, the FCA recently put out proposed changes for the self-invested personal pension market. The consultation on those proposals closes August 24, 2026. SIPPs give savers more control over where their pension money gets invested, and the market has grown considerably over the past decade. What specific changes the FCA is proposing for SIPPs wasn’t fully detailed in the review, but the timing is clearly deliberate — the regulator is working across multiple pension product categories at once.
The SIPP consultation is part of the FCA’s broader Pensions Regulatory Priorities, which frames modernizing long-term savings as an ongoing regulatory commitment rather than a one-off review.
Worth noting: the FCA’s push on legacy products isn’t just about fees. It’s also about data. Firms with poor data management can’t properly compare outcomes across different customer groups — and if you can’t measure the disparity, you can’t fix it. The regulator wants providers to benchmark outcomes across product types and customer segments to spot where people are getting a raw deal. Some firms probably don’t love that level of scrutiny on their closed books.
The industry is now waiting on further guidance as reforms work through approval and implementation. No firm deadlines were set for the legacy product improvements beyond the existing consultation window for SIPPs.
And the FCA’s message to slower-moving providers is pretty clear: the firms already doing this work are proving it’s possible. There’s no credible excuse left for the ones that aren’t.
The consultation on self-invested personal pension market changes closes August 24, 2026.
Frequently Asked Questions
What specific problems did the FCA find with legacy pension products?
The FCA found complex charging structures, outdated product designs, and poor data management in closed legacy pension products, leading to worse outcomes for some holders compared to customers in newer products.
Who at the FCA is leading the push on legacy pension reform?
Charlotte Clark, the FCA’s director of cross-cutting policy and strategy, has been the named voice on the legacy pension product review and the call for industry action.
