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FCA CP25/39: Flexible digital projection tools and mandatory DC-to-DC transfer comparisons to strengthen consumer protection in a DC-dominated pensions market; final rules expected H2 2026

Published on: 11 December 2025

Published by a LexisNexis Pensions expert
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FCA Consultation Paper CP25/39: Updating our requirements for a changing pensions market

News summary

CP25/39 outlines FCA plans to refresh pensions regulation in light of the rapid swing to a DC-led market, where savers carry greater responsibility for retirement choices. Building on DP24/3 and allied reforms - the Value for Money framework, pensions dashboards and targeted support - the FCA intends to modernise rules to better enable informed decision-making. It proposes a more adaptable regime for digital pension projection tools to help members grasp options and likely outcomes, alongside a mandatory comparison step for non-advised DC-to-DC transfers so consumers can weigh charges, investment options and any potential loss of benefits before acting. While this adds time at the outset, the FCA expects better outcomes, fewer abandoned transfers and stronger competition. Proposals on self-invested personal pensions (SIPPs) are due in early 2026. The FCA will behaviourally test the transfer measures, monitor outcomes under the Consumer Duty, and aims to publish final rules in the second half of 2026.

What has happened?

On 11 December, the FCA opened Consultation Paper CP25/39 ‘Adapting our requirements for a...

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