Pension Transfer Specialist: The Qualification Route

A pension transfer specialist (PTS) is the person an FCA-regulated firm must use to give or check advice on pension transfers, conversions and opt-outs. To become one, you currently need two things under the FCA's Training and Competence rules: a pension transfer qualification (for most people the CII's AF7 unit, which forms the Level 6 Award in Regulated Pension Transfer Advice) and a full retail investment advice qualification. Your firm must also assess you as competent. The older AF3 route is withdrawn. This guide covers the UK position as set out in the FCA Handbook and by the CII, checked on 15 October 2026.

What a pension transfer specialist does

According to the FCA Handbook (COBS 19.1.1A R), a firm must make sure that advice on pension transfers, conversions and opt-outs is given or checked by a pension transfer specialist. The rule does not apply where the only safeguarded benefit is a guaranteed annuity rate. FCA guidance (FG21/3) adds that for guaranteed annuity rate transfers there is no requirement to use a PTS.

Where a firm uses a PTS to check its proposed advice, COBS 19.1.1B G says the PTS should check the advice is complete, confirm any personal recommendation is suitable, and confirm in writing that they agree before it goes to the client. The Handbook also sets the starting point for suitability (COBS 19.1.6 G): for safeguarded benefits, a firm should start by assuming a transfer, conversion or opt-out will not be suitable, and should only consider it suitable if it can clearly demonstrate that on contemporary evidence.

The firm carries the responsibility. FG21/3 says a firm with the full pension transfer permission must take responsibility for the defined benefit transfer advice given by its PTS. A limited permission covers only transfers from guaranteed annuity rates. So “PTS permission” is really two things: the firm’s permission, and the individual’s assessed competence and qualifications.

The qualification requirement

TC 2.1.7A R says that before acting as a pension transfer specialist, an employee must attain each module of both the pension transfer qualification and the personal recommendations qualification. TC 2.1.5K R says the same thing from the competence side: an employee may not be assessed as competent for activity 11 (the PTS activity in TC Appendix 1) until they hold each module of a qualification for personal recommendations on retail investment products, in addition to the activity 11 qualification. The guidance (TC 2.1.5L G) says a PTS must be qualified to the same standard as someone giving investment advice to retail clients. These provisions took effect on 1 October 2021.

The history, briefly: the FCA announced in October 2018 that PTSs would need a retail investment advice qualification as well as a pension transfer qualification. The FCA later delayed the change because of coronavirus disruption to exams, and the FCA's policy statement page gives the new date as 1 October 2021.

Which investment advice qualification counts is covered in our guide to appropriate qualifications for retail investment advisers, so we do not repeat it here. The CII lists examples of what it calls RDR-compliant qualifications, including its Level 4 Diploma in Regulated Financial Planning.

Pension transfer qualifications in the FCA table

The FCA's appropriate qualification tables (TC Appendix 4) list the pension transfer qualifications for activity 11. They include the following, each with the condition shown:

The table also contains other and older entries, and it can change. Read the live version of TC Appendix 4.1 before you choose, because some entries are conditional and the awarding body for some lines is not repeated in the table.

Where AF3 fits

People still search for “AF3”. According to the CII, AF3 (Pension planning) was a unit of its Advanced Diploma in Financial Planning. The CII says AF3, along with G60 and the older Fellow or Associate route, has been withdrawn and is not available to new entrants. Existing holders can still use it, but only if it is combined with an RDR-compliant qualification. CII materials say AF3 was withdrawn in April 2018 and replaced by AF7 and AF8, and that AF7 is not equivalent to AF3. For anyone starting now, AF7 is the CII route.

The CII AF7 unit and Level 6 Award

According to the CII, the Level 6 Award in Regulated Pension Transfer Advice has one core unit, AF7 Pension transfers, worth 20 CII credits. The CII says it is aimed at retail investment advisers who want to do pension transfer work and become pension transfer specialists, and also suits paraplanners, technical consultants and planning support staff. No formal entry requirements are listed, though the CII says it assumes knowledge from units R04 (Pensions and Retirement Planning) and J05 (Pension Income Options), or equivalent. The recommended study time is 100 hours, which varies with experience.

The CII also says candidates are expected to know the FCA rules on training and competence, conduct of business and complaints handling. Fees are not shown on the CII page we read, so check the CII shop for the current price.

The CII adds that a statement of professional standing (SPS) is not needed for activity 11, because it is a non-RDR activity. If you are also a retail investment adviser, the adviser rules still apply: see our guide to the statement of professional standing.

Supervision, competence and CPD

• Supervision. Under TC 2.1.5R, where an employee is not yet assessed as competent and acts as a pension transfer specialist, the supervising individual must hold an appropriate qualification.
• Competence. A firm can assess a PTS as competent only once the PTS has shown the necessary competence and holds the relevant qualifications (FG21/3, paragraph 2.51), and must review competence regularly.
• CPD. TC 2.1.23A R requires at least 15 hours of appropriate CPD in each 12-month period, of which at least 9 hours must be structured and at least 5 hours must come from an external independent provider. The requirement is pro-rated in the first year. It is in addition to other CPD, and CPD unrelated to the PTS role does not count.
• Records. Firms must keep records of PTS CPD and any suspensions (TC 2.1.24R), and must not stop a PTS getting a copy of their own records.
• Certification. FG21/3 says PTSs fall under the Certification Regime, so firms must certify at least once a year that each PTS is suitable for the role.

The 35-hour adviser rule is different from the PTS rule; our guide to adviser CPD explains the adviser requirement.

Frequently asked questions

Is AF3 still a valid pension transfer qualification?

Only for existing holders, and only combined with an RDR-compliant qualification. It is withdrawn and not open to new entrants, according to the CII.

Do I need a retail investment advice qualification as well?

Yes. TC 2.1.5K R and TC 2.1.7A R require both a pension transfer qualification and a personal recommendations qualification.

Is a pension transfer specialist a regulated permission?

The permission sits with the firm. According to FG21/3, a firm with the full pension transfer permission takes responsibility for the advice, and the individual must be assessed as competent by the firm and hold the required qualifications.

How many CPD hours does a PTS need?

At least 15 hours in each 12-month period, with at least 9 structured and at least 5 from an external independent provider.

Does this apply across the UK?

FCA rules apply to FCA-authorised firms across the UK. The CII says AF7 exams are based on English law and practice.

Where to start

Check you hold, or are working towards, a retail investment advice qualification. Then look at the CII AF7 unit and the live FCA table, and speak to your compliance team about how your firm will assess you. For general CPD resources, see the Learnsignal CPD hub.

This article is general information, not regulatory, legal or compliance advice. Pension transfer rules change, so check the FCA Handbook and the CII before relying on it, and speak to your compliance team.