Navigating UK SIPP and DC pension changes: what fund managers and trustees need to know

The Financial Conduct Authority (FCA) has introduced reforms to self-invested personal pensions and defined contribution schemes, which took effect from 31 October 2025.

These changes highlight the importance of trustee accountability, product governance and the transparency expected from fund offerings linked to pension assets.

What has changed? 

The new FCA framework brings: 

• value for money assessments and stricter reporting requirements for defined contribution (DC) schemes
• enhanced duty of care, annual governance reviews and stricter vetting for self-invested personal pensions (SIPPs)
• increased liability for trustees when selecting and monitoring investment options.
• the FCA’s goal is clear, limit high-risk or unsuitable investments and enforce stronger consumer protection for pension savers

Who does this affect and what do you need to do?

UK fund managers and intermediaries

If you manage or promote funds for UK pension schemes, you must:

• align fund documentation and strategy to meet new value for money tests and governance standards
• prepare transparent disclosures on fees and risks, suitable for scrutiny by trustees and regulators
• review product structures to ensure compliance, especially in relation to non-standard assets
• larger managers may benefit from scale, but smaller firms need to reconsider their market positioning, adapt, or focus their expertise 

Fund managers offering to UK pension investors 

Offshore firms, such as those based in Ireland or Luxembourg, seeking UK pension capital must: 

• ensure products, reporting and service provider relationships meet the FCA’s standards
• be prepared to evidence compliance, even if not UK-based

Trustees and DC scheme administrators 

Trustees now face heightened regulatory scrutiny and must:

• maintain clear, documented investment decisions
• evidence ongoing due diligence, suitability and liquidity
• conduct annual reviews of products offered to retirement clients 

Why location still matters

Jurisdictional credibility supports trustee confidence and regulatory compliance. Ireland’s collective asset management vehicles (ICAVs) and Qualifying Investor Alternative Investment Funds (QIAIFs) and Luxembourg’s Reserved Alternative Investment Fund (RAIF) and Undertakings for Collective Investment in Transferable Securities (UCITS), for example, offer strong frameworks and governance for pension-focused funds. 

What is next? 

If your business has exposure to UK pension capital, these reforms require immediate attention. Review your structures, align your governance and reporting and ensure your offerings meet the new standards to remain competitive and compliant. 

Ogier Global’s cross-jurisdictional fund services can help you navigate these regulatory changes with clarity and operational precision. For tailored support, reach out to our team.

About Ogier

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Disclaimer

This client briefing has been prepared for clients and professional associates of Ogier. The information and expressions of opinion which it contains are not intended to be a comprehensive study or to provide legal advice and should not be treated as a substitute for specific advice concerning individual situations.

Regulatory information can be found under Legal Notice