There is a specific rule requirement to disclose any possible disadvantages in the suitability report. The rule (COBS 9.4.7) can be seen here: http://fshandbook.info/FS/html/FCA/COBS/9/4.
Remember that a disadvantage is different to a risk. For example, there is a risk that investments can fall in value, whereas a disadvantage would be that the recommended product has higher charges than the product being replaced.



FCA letter to DB Transfer firms
Alistair MacDougall Compliance 2019, FCA, Pension, Pension Transfer
The FCA is writing to around 1700 firms requesting that firms review their transfer advice processes and report back.