CP26/20: FCA consults on SIPP due diligence and asset protection rules, closing 24 August 2026

Action required. SIPP operators should read this consultation and consider submitting a response before 24 August 2026.

The FCA published CP26/20 on 22 June 2026, consulting on substantive rule changes for self-invested personal pension (SIPP) operators. The consultation closes on 24 August 2026. The FCA also proposes to retire its 2013 non-Handbook guidance FG13/8 on SIPP operators in light of the new proposals.

The paper covers two distinct areas. First, new due diligence requirements designed to reduce scam and fraud risk. Second, a new Pension Scheme Money and Assets (PSM&A) regime to ensure firms protect and accurately record pension scheme money and assets where they use unauthorised trustees.

The SIPP market held assets under administration of approximately 567bn across 5.3 million consumers in 2024, accounting for around a third of assets in FCA-regulated defined contribution pensions. The FCA has historically found cases of poor due diligence, weak record keeping, and gaps in how firms protect money and assets in this market.

Due diligence proposals

The proposed rules would require SIPP operators to carry out initial and ongoing due diligence on third parties that introduce members or facilitate investments, and on investments they are instructed to arrange to be acquired for a scheme. The standard required is that firms form a reasonable understanding of the nature and risks of investments, so they do not accept investments that unduly expose consumers to the risk of harm from scams and fraud or investment propositions that lack credibility.

Firms would also be required to establish governance, management information, and record-keeping processes to demonstrate compliance. This is consistent with firms' existing obligations under the Senior Management Arrangements, Systems and Controls sourcebook (SYSC). The FCA proposes a 12-month implementation period for the due diligence changes.

PSM&A regime

The new PSM&A regime would set minimum standards requiring firms to ensure pension scheme money and assets are securely held, accurately recorded, and subject to effective oversight. The FCA notes that CASS rules do not apply to SIPP operators. The PSM&A regime is not an extension of CASS; it is a new, distinct set of minimum standards intended to address the inconsistency in how firms have voluntarily mirrored CASS protections, which the FCA found has been done to varying standards. Given the scope of the changes, the FCA proposes a two-year implementation period before these requirements come into force.

Who is affected

The consultation is primarily relevant to the following firm types:

• firms that operate personal pension products (both accumulation and decumulation)
• investment platform providers and stockbrokers
• firms offering discretionary investment services
• third-party custodians and platforms
• trustees of defined contribution occupational pension schemes
• auditors and insolvency practitioners
• trade bodies for regulated firms

If your firm does not operate SIPPs or provide services to SIPP operators, this consultation is not relevant to you.

Context

CP26/20 follows Discussion Paper DP24/3, published in December 2024, in which the FCA sought views on its regulatory framework for SIPPs and received responses from firms, consumer bodies, and trade associations. The FCA states the proposals are intended to raise consistency across the market, where it has found standards have varied.

The consultation closes on 24 August 2026.