The Department for Work and Pensions has opened a consultation on changes to the Occupational and Personal Pension Schemes (Conditions for Transfers) Regulations 2021, with a targeted proposal aimed at pension scam activity involving Small Self-Administered Schemes. According to the department, the change would add a new safeguard where a saver cannot show a clear link to the SSAS receiving the transfer. The policy case is direct. Pension scam cases can leave savers with losses that cannot be recovered, and ministers say misuse of SSAS has become a specific concern. Government material published alongside the consultation says average losses in these cases have risen to £38,400 per person.
Under the proposal, the absence of a clear link between the member and the receiving SSAS would trigger a warning flag. That would allow the transfer to be stopped, giving trustees and scheme administrators a clearer route to intervene where the risk indicators are already strong. This is a narrower change than a full rewrite of transfer law. The department is not proposing to treat every SSAS transfer as suspect, but to create a defined safeguard for cases where the relationship between the saver and the receiving scheme cannot be properly demonstrated.
The consultation is also notable for what it would remove. The Department for Work and Pensions says it wants to cut administrative friction that has been delaying legitimate pension transfers, particularly where there is no evidence of fraud. That reflects a recurring concern from schemes and advisers that anti-scam controls can draw routine cases into lengthy checks. That balance matters because the 2021 regulations were introduced to let trustees pause or refuse transfers where scam indicators are present, and a review published in 2023 found them broadly effective. The same review also identified unnecessary complexity, giving ministers a basis for targeted amendment rather than full replacement.
Torsten Bell, the Minister for Pensions, has framed the consultation as an early step in a wider anti-fraud programme rather than a single technical adjustment. The department's position is that pension scams do more than reduce savings: they can remove the retirement income members expected to rely on, which strengthens the case for earlier intervention where warning signs are already clear. The Pensions Regulator has also backed the proposed direction. Speaking on behalf of the Pension Scams Action Group, Gaucho Rasmussen said the safeguard would be a useful step and encouraged trustees and administrators to respond. That support is significant because the group brings together the regulator, government, law enforcement and industry bodies in a joint effort to identify emerging risks and disrupt scam activity.
For trustees, administrators and pension professionals, the practical effect would be twofold. Transfers into SSAS could face a more explicit fraud test where the member's connection to the receiving scheme is unclear, while lower-risk transfers elsewhere could move with fewer procedural delays if ministers proceed with the simplification set out in the consultation. For savers, the impact is more targeted than universal. Members making a legitimate transfer may benefit from a process that is easier to complete when no fraud indicators are present, but those moving into arrangements that do not clearly fit their circumstances are likely to face earlier challenge. In policy terms, that is the central trade-off: tighter intervention where risk is concentrated, with less friction where it is not.
The consultation published on GOV.UK invites views from trustees, scheme members, administrators and other pensions professionals on both the new SSAS safeguard and the proposed reduction in transfer red tape. It is presented as the first step in a wider programme on pension transfer reform and pension scams. Further work is expected during 2026, including longer-term measures and possible primary legislation. That gives the current exercise added weight. Responses will not only shape a technical amendment to the 2021 regulations, but may also inform the next phase of anti-fraud policy across the pensions system.