The FCA’s CP26/20 consultation marks a significant regulatory shift for SIPP operators and the wider pensions ecosystem. It proposes more prescriptive requirements for enhanced due diligence, pension scheme money and asset protection, record keeping, reconciliation, governance and operational resilience.

The consultation responds to FCA concerns about inconsistent market practices, weak oversight of introducers and third parties, poor trustee bank account controls, inadequate books and records, delayed discrepancy identification, and consumer exposure to scams, fraud and unsuitable investments.