UK Pension Transfer Delays: UK Pension Provider Complaints Compared

Last updated 20 May 2026

Transferring a UK pension to New Zealand is rarely instant. Even when the receiving scheme is a valid QROPS, the process can involve valuations, discharge forms, due diligence checks, scam-prevention questions, identity documents, tax timing and back-and-forth between the UK provider, the adviser and the receiving New Zealand scheme.

For many clients, the most frustrating part is not that paperwork is required. It is the silence: forms not being issued, emails not being answered, completed paperwork not being acknowledged, or the provider failing to explain what is still outstanding.

To understand where UK pension transfer delays and service issues may be more likely, QROPS NZ analysed three sources of evidence:

1. FCA 2025 H2 complaints data for major UK pension providers and platforms.
2. QROPS NZ’s own transfer-time analysis of 1,500 UK pension transfers to New Zealand from 2014 to 2024.
3. Real anonymised QROPS transfer complaint outcomes reviewed by QROPS NZ.

This article should be read alongside our guides on transferring a UK pension to New Zealand, what a QROPS is, the QROPS transfer process, UK pension transfer to New Zealand tax rules and UK pension transfer times.

Key findings

Among providers with more than 100,000 estimated active pension policies or service users, Embark had the highest complaint ratio in our analysis at 6.53 complaints per 1,000 estimated pension policies, followed by Countrywide Assured, Quilter, St. James’s Place and Vanguard.

At the lower end of the complaint-ratio table were Bank of Scotland, HSBC UK Bank, Lloyds Bank, People’s Partnership / The People’s Pension and NFU Mutual.

Complaint ratio is only one part of the picture. A provider with a low complaint ratio can still be difficult in a specific transfer. A provider with a higher ratio may be dealing with more legacy pensions, more complex arrangements or more transfer cases.

That is why we also looked at:

• the percentage of complaints upheld;
• how quickly complaints were resolved;
• QROPS NZ’s actual transfer-time experience;
• real complaint outcomes and compensation payments.

The FCA’s 2025 H2 firm-level complaints data includes firms that reported at least 500 complaints during the six-month period, or 1,000 complaints over an annual reporting period. The FCA also publishes contextual metrics that allow complaints to be compared against the number of accounts, policies or relevant service users. 

UK pension provider complaints table

The table below only includes providers with more than 100,000 estimated active pension policies or service users.

We calculated the complaint ratio as:

Complaints opened ÷ estimated active pension policies × 1,000

Provider	Complaints	Est. pension policies	Complaints per 1,000 policies	Upheld %	Resolved within 3 days–8 weeks
Embark	1,149	176,000	6.53	86.04%	41.34%
Countrywide Assured	462	109,000	4.24	43.61%	39.10%
Quilter	1,140	276,000	4.13	59.35%	99.18%
St. James’s Place	2,621	639,000	4.10	48.35%	54.57%
Vanguard	569	176,000	3.23	63.09%	69.46%
Prudential / M&G	6,508	2,292,000	2.84	84.43%	78.59%
Zurich	764	277,000	2.76	38.10%	71.43%
Liverpool Victoria / LV=	421	165,000	2.55	83.33%	45.77%
Hargreaves Lansdown	2,262	901,000	2.51	55.92%	77.91%
AJ Bell	1,367	553,000	2.47	52.19%	63.17%
Interactive Investor	265	111,000	2.39	53.71%	86.03%
Phoenix / ReAssure	17,134	7,926,000	2.16	79.37%	55.56%
Aviva	17,892	8,480,000	2.11	68.41%	65.90%
Fidelity / FIL	1,237	610,000	2.03	51.98%	66.27%
Aegon / Scottish Equitable / Cofunds	5,328	3,197,000	1.67	65.28%	49.94%
Royal London	5,817	3,705,000	1.57	67.36%	64.68%
Legal & General	1,519	1,168,000	1.30	75.31%	84.13%
Rothesay	553	517,000	1.07	24.96%	79.79%
Scottish Widows	5,592	5,275,000	1.06	84.87%	71.52%
Canada Life	324	450,000	0.72	78.13%	82.29%
NFU Mutual	74	104,000	0.71	56.58%	98.68%
People’s Partnership / The People’s Pension	2,731	7,586,000	0.36	50.22%	82.68%
Lloyds Bank	50	172,000	0.29	36.96%	67.39%
HSBC UK Bank	66	330,000	0.20	56.92%	56.92%
Bank of Scotland	13	130,000	0.10	30.00%	60.00%

The data comes from the UK FCA and our analysis of public data on the schemes.

For this filtered group, the combined result was 75,858 complaints across approximately 45.3 million estimated pension policies or service users, equal to 1.67 complaints per 1,000 policies.

Methodology

This analysis used the FCA’s 2025 H2 firm-level complaints data for decumulation and pensions.

Where the FCA gave a contextual complaints rate, we estimated active pension policies or service users using this formula:

Estimated policies = complaints opened ÷ FCA contextual complaint rate × 1,000

Where providers appeared under multiple legal entities, we aggregated obvious provider groups. For example, Phoenix and ReAssure were combined, and Aegon was combined with Scottish Equitable and Cofunds.

For aggregated providers, the upheld percentage and complaint-resolution percentage were calculated using a complaint-count weighted average.

This means the table should be read as a practical service-quality indicator, not a perfect league table. FCA context metrics are not always the same as an official provider-published active policy count.

What the complaint ratio shows

Complaint numbers alone can be misleading.

For example, Aviva and Phoenix / ReAssure had high absolute complaint numbers, but they also have very large estimated policy books. Their complaint ratios are therefore closer to the overall average than their raw complaint totals might suggest.

By contrast, Embark, Countrywide Assured, Quilter, St. James’s Place and Vanguard had higher complaint ratios once adjusted for estimated policy numbers.

That does not prove that every transfer from those providers will be slow or problematic. But it does make the data more useful than simply asking which firms received the most complaints.

Why upheld rates matter

The upheld rate shows the percentage of closed complaints where the firm accepted, at least in part, that the customer’s complaint was valid.

This matters because a high complaint ratio combined with a high upheld rate suggests more than customer frustration. It may suggest that the provider itself accepted that something had gone wrong.

In this table, Embark, Prudential / M&G, Liverpool Victoria / LV=, Scottish Widows, Legal & General and Canada Life had relatively high upheld rates.

For someone transferring a UK pension to New Zealand, this matters because many transfer problems are practical rather than technical. A provider might eventually process the transfer, but the client may still suffer delays, repeated paperwork requests, unclear instructions or poor updates along the way.

Why complaint resolution speed matters

For a QROPS transfer, speed matters. A delay can affect tax timing, exchange-rate decisions, investment exposure and wider retirement planning.

The FCA complaints data reports complaints closed within three days and complaints closed after three days but within eight weeks. Across all financial services complaints in 2025 H2, the FCA reported that 44.77% of complaints were closed within three days, 49.67% were closed after three days but within eight weeks, and 5.56% took more than eight weeks. 

In our provider table, resolution speed varied widely. Quilter, NFU Mutual, Interactive Investor, Legal & General, People’s Partnership / The People’s Pension and Canada Life had stronger resolution-speed results.

By contrast, Embark, Countrywide Assured, Liverpool Victoria / LV=, Aegon / Scottish Equitable / Cofunds and St. James’s Place had weaker results.

This does not mean those providers will necessarily delay a transfer. But it does show that complaint handling speed varies materially between providers.

What UK pension complaints are usually about

Public complaint data is useful, but it does not always explain what actually went wrong in a client’s pension transfer.

The Financial Ombudsman Service says personal pension complaints can involve mistakes running a scheme, problems accessing money, pension transfer issues, investment changes or advice concerns. 

For pension transfers, the most relevant complaint themes are usually:

Complaint theme	Why it matters for QROPS transfers
Slow response times	Delays valuations, forms, due diligence checks and final payment.
Poor communication	Leaves the client unsure what is happening or what is still needed.
Administration errors	Can mean forms are lost, sent late, sent to the wrong place or not acknowledged.
Unclear transfer requirements	Makes it harder to complete the provider’s process correctly.
Due diligence delays	May be regulatory, but can still become excessive if poorly managed.
Incorrect or incomplete information	Can affect advice, tax planning and transfer timing.
Failure to escalate	Repeated follow-ups may be ignored until a formal complaint is raised.

In our QROPS transfer work, the common pattern is clear: the problem is often not that the transfer is impossible. It is that basic administration and communication fail before the transfer is completed.

How this compares with QROPS NZ’s transfer-time research

Public complaint data shows complaint volumes, upheld rates and resolution speed. It does not show how long a UK pension transfer to New Zealand actually takes.

QROPS NZ has separately analysed 1,500 UK pension transfers to New Zealand between 2014 and 2024. That analysis measured the period from when the member completed the UK transfer forms until the money arrived in the New Zealand QROPS scheme. It also noted that simply getting the forms can itself take months. 

That transfer-time research found:

QROPS NZ finding	What it means
Average transfer times were around 50–65 days from 2014 to 2016.	Earlier transfers were often completed within two months.
By 2017, average transfer times had risen to nearly 70 days.	Transfers were already becoming slower before the most recent regulatory changes.
Some recent transfers exceeded 100 days.	Long transfer times are now a real planning risk.
The slowest cases exceeded 150 days.	Some provider delays are long enough to affect tax timing, investment exposure and retirement planning.

QROPS NZ’s previous transfer-time analysis identified faster providers including Clerical Medical, Zurich, ReAssureand Standard Life. It identified slower providers including Sun Life Financial of Canada, Scottish Widows, Royal London, Phoenix Life Limited, Aviva and Aegon, with the slower group taking well over 100 days in the analysed cases. 

This is important because complaint data and transfer-time data do not always match perfectly.

For example, Zurich had a higher complaint ratio than some large providers in the FCA complaints table, but it appeared in QROPS NZ’s faster-provider group for historic transfer times. ReAssure also appeared in the faster-provider group historically, while Phoenix / ReAssure as an aggregated group had a higher upheld rate and weaker complaint-resolution speed in the FCA complaints table.

The practical conclusion is not that one provider is always good or always bad. The better conclusion is that provider experience depends on the policy type, legacy system, administrator, due diligence requirements and the quality of communication during the transfer.

How complaint data compares with real transfer-time experience

Provider	Complaint ratio	Upheld %	Resolution speed	QROPS NZ transfer-time experience
Aviva	2.11	68.41%	65.90%	Previously appeared on QROPS NZ slower-provider list.
Phoenix / ReAssure	2.16	79.37%	55.56%	Mixed: Phoenix appeared slower; ReAssure appeared faster.
Scottish Widows	1.06	84.87%	71.52%	Previously appeared on QROPS NZ slower-provider list.
Royal London	1.57	67.36%	64.68%	Previously appeared on QROPS NZ slower-provider list.
Aegon / Scottish Equitable / Cofunds	1.67	65.28%	49.94%	Aegon previously appeared on QROPS NZ slower-provider list.
Zurich	2.76	38.10%	71.43%	Previously appeared on QROPS NZ faster-provider list.

This gives a more balanced picture than a simple ranking.

FCA data helps identify complaint levels and outcomes. QROPS NZ transfer-time data helps show what happens in real transfers to New Zealand. Real complaint letters show what the delays actually look like when something goes wrong.

What real QROPS transfer complaints show

Public FCA data tells us how many complaints were opened, how many were upheld and how quickly complaints were resolved. It does not show the practical detail of what actually happens inside a delayed QROPS transfer.

QROPS NZ’s review of real UK pension transfer complaint responses shows a repeated pattern. The most common issues are administrative:

• missed service targets;
• delayed forms;
• failure to respond to emails;
• completed paperwork not being acknowledged;
• documents sent by post when email was requested;
• transfer requests being passed between teams without clear ownership;
• unclear explanations about what was still required.

In one Aviva case, the provider accepted that it missed a 10-working-day target for issuing QROPS transfer forms, failed to respond promptly to a question about whether forms could be returned by email, and then failed to provide updates after completed forms were received. Aviva offered an inconvenience payment and said it would complete a loss assessment if the transfer proceeded. 

In a ReAssure case, the provider accepted that the time taken to transfer pension funds had fallen short of expected service standards. ReAssure referred to high customer demand as one reason responses were taking longer than normal, offered an apology payment, and said it would investigate whether the delay caused financial loss. 

In a Wesleyan case, the complaint was upheld after QROPS form requests were delayed and the provider said the request appeared to have been “lost in translation” between teams. The provider accepted that expectations had not been managed properly and offered compensation for distress and inconvenience. 

In an XPS case, the administrator acknowledged that service levels had not been met, apologised for lack of service and transfer delays, and confirmed that daily interest had been included at 1% above the Bank of England base rate from the guarantee date to the payment date. 

In a Phoenix case, the complaint was upheld where information had been sent by post even though email had been requested as the preferred communication method. That kind of issue may sound small, but in an overseas pension transfer it can create practical delay because the client, adviser, UK provider and New Zealand receiving scheme may all be operating across different systems and time zones. 

These examples are consistent with what we see in practice: overseas pension transfers can be delayed by very ordinary administration failures.

Some delays are regulatory. Others are avoidable.

It is important to be fair to UK pension providers. Not every transfer delay is poor service.

UK pension providers are required to carry out due diligence. They may need to check whether the receiving scheme is a valid QROPS, whether scam-warning rules apply, whether safeguarded benefits exist, whether advice is required, and whether the transfer request creates a regulatory red flag.

That can take time.

But there is a difference between regulatory due diligence and avoidable poor administration.

Prudential’s complaint response is a useful example. The provider said pension scams legislation required it to decline a statutory transfer request where a “Red Flag” was present, and that it had no discretion to set that red flag aside. However, Prudential also accepted failures around communication, delays and complaint handling, including not clearly explaining that a new transfer request could still be submitted if no red flags were present. 

That distinction matters.

A provider may be justified in asking due diligence questions. It is not necessarily justified in failing to respond, missing its own service standards, sending unclear instructions or taking months to explain what is happening.

What compensation can usually be expected?

A successful pension complaint does not automatically lead to large compensation.

In the complaint responses reviewed by QROPS NZ, providers usually separated two issues.

First, they may offer a modest payment for distress, inconvenience or poor service.

Second, if the delay may have caused actual financial loss, they may carry out a separate financial loss assessment.

In the QROPS transfer complaints reviewed, apology payments for distress and inconvenience were often modest. Payments commonly sat between £75 and £350, depending on the facts of the case, the seriousness of the service failure and whether the provider accepted wider complaint-handling failures.

Observed compensation outcomes in QROPS transfer complaints

These examples are drawn from anonymised complaint responses reviewed by QROPS NZ. They should not be treated as guaranteed compensation outcomes.

Complaint issue seen in QROPS transfer cases	Provider example	Outcome seen	What it suggests
Delayed back-dated valuation	Aviva	£90 total, including £75 apology payment and £15 conversion cost	Small administration delays often result in modest inconvenience payments.
Delay issuing QROPS transfer forms and poor email response	Aviva	£265, including £15 conversion cost	Missed service standards and poor communication can lead to higher apology payments.
Delay transferring pension funds	ReAssure	£200	Transfer delay complaints may produce a modest payment, with financial loss assessed separately.
Delayed forms at start of withdrawal / QROPS journey	ReAssure Life	£100	Even where the transfer is complex, providers may compensate for avoidable early-stage delay.
Delayed QROPS information and requests lost between teams	Wesleyan	£75	Lost or delayed paperwork often produces low-level distress/inconvenience compensation.
Complaint handling failures, delay and unclear transfer explanation	Prudential	£350	More serious complaint-handling failures can lead to higher inconvenience compensation.
Transfer payment delay after service standards not met	XPS	Interest at 1% above Bank of England base rate	Where a transfer value is paid late, redress may include interest rather than only an apology payment.

The pattern is clear: inconvenience payments are usually modest. The more important question is whether the delay caused measurable financial loss.

That could include:

• a transfer value being paid late;
• loss of investment opportunity after funds should have been transferred;
• interest owed between the guarantee date and payment date;
• additional tax exposure caused by timing;
• avoidable currency or market-timing impact;
• costs caused by repeated requests or errors.

Where financial loss is possible, providers may need information from the receiving scheme to compare what actually happened with what should have happened. In one Aviva response, the provider said it would create a timeline and write to the receiving scheme for details of the investments made before completing a loss assessment. 

In another ReAssure response, the provider said it had written to the new pension provider to gather additional information before deciding whether any further payment was due. 

What to do if your UK pension transfer is delayed

If your UK pension transfer to New Zealand is delayed, the first step is not always to complain immediately. Sometimes the provider is waiting for a document, identity check, receiving-scheme declaration or due diligence answer.

But if the provider is not responding, has missed its own service standards, or cannot clearly explain what is outstanding, a formal complaint may be appropriate.

UK pension providers generally have eight weeks to respond to a complaint before it can usually be escalated. Government guidance also confirms that pension providers have to respond within eight weeks. 

Before complaining, gather:

Evidence	Why it matters
Date transfer forms were requested	Shows when the provider’s service clock may have started.
Date forms were issued	Helps prove delay in sending documents.
Date completed forms were returned	Shows when the provider had the information.
Copies of follow-up emails	Shows lack of response or poor communication.
Transfer value or guarantee date	Helps calculate possible financial loss.
Receiving scheme details	Helps prove where funds should have been transferred.
Tax residency and timing details	Important if transfer timing affects New Zealand tax.
Notes of phone calls	Useful if updates were given verbally but not confirmed.

If the matter is serious, ask the provider to confirm:

• what documents are still outstanding;
• whether the transfer is being held for regulatory due diligence;
• whether a red flag or amber flag has been identified;
• whether the transfer can proceed if further information is supplied;
• whether a financial loss assessment will be completed;
• whether the complaint is being treated as a regulated complaint;
• when a final response will be issued.

Why this matters for people moving UK pensions to New Zealand

A UK pension transfer delay can be more than an inconvenience.

For a person transferring a UK pension to New Zealand, timing can affect:

• whether the transfer falls inside or outside New Zealand’s transitional resident exemption;
• how taxable income is calculated under the schedule method or formula method;
• whether funds are exposed to UK or New Zealand investment markets for longer than expected;
• whether a guaranteed transfer value expires;
• whether exchange rates move before the funds arrive;
• when retirement income planning can begin.

This is why we strongly recommend getting advice before starting a UK pension transfer. It is not enough to know that a pension can be transferred. You also need to understand the transfer process, the provider’s requirements, the receiving QROPS rules, tax timing and the practical risks of delay.

For more detail, read our guides on UK pension transfer to New Zealand tax rules, pension transfer traps and risks and which UK pensions can be transferred to New Zealand.

How to interpret this table

This article should not be read as a simple league table of “good” and “bad” pension providers.

There are important limitations:

1. The FCA firm-level complaints table only includes firms that meet the FCA’s publication thresholds.
2. Some providers operate through multiple legal entities, so we have aggregated obvious provider groups where appropriate.
3. Estimated active policy counts are based on FCA contextual complaint metrics, so they should be treated as estimates.
4. Some businesses are platforms, administrators or advice entities rather than traditional pension providers.
5. A high complaint ratio does not mean every transfer from that provider will be problematic.
6. A low complaint ratio does not guarantee a fast transfer.
7. Complaint data does not show every cause of delay inside an individual QROPS transfer.
8. Historic transfer-time experience does not guarantee future provider performance.

The data is most useful as a risk indicator. It shows where complaint experience, upheld rates, resolution speed and historic transfer-time experience may deserve closer attention.

The QROPS NZ view

The most frustrating QROPS transfer delays we see are not always caused by complex pension rules.

They are often caused by simple administration failures: forms not being issued, emails not being answered, documents being sent by post instead of email, completed forms not being acknowledged, or no one confirming what is still outstanding.

A formal complaint can help move a case forward, but clients should not expect large compensation unless they can show actual financial loss. In many cases, providers offer modest payments for inconvenience while separately considering whether the client lost out financially.

The key is preparation. The more complete the transfer file is at the start, the harder it is for avoidable administration issues to derail the process.

Final takeaway

The providers with the highest complaint ratios in this analysis were Embark, Countrywide Assured, Quilter, St. James’s Place and Vanguard.

The providers with the lowest complaint ratios among those with more than 100,000 estimated policies were Bank of Scotland, HSBC UK Bank, Lloyds Bank, People’s Partnership / The People’s Pension and NFU Mutual.

But for anyone transferring a UK pension to New Zealand, the more important lesson is this:

UK pension transfer delays are often caused by paperwork, communication failures and provider process issues — not just by pension rules.

If you are planning a transfer, make sure you understand the provider’s process, the QROPS requirements, the New Zealand tax position and the timing risks before you start.