PS18/20 introduced rules to raise qualification levels for pension transfer specialists (PTSs) to require them to obtain the same qualification as an investment adviser, alongside the existing PTS qualification. The implementation of these rules was delayed by a year due to coronavirus, but will come into force from 1 October 2021. Any PTSs who are yet to complete their qualifications will need to ensure that they are appropriately qualified by that date to continue advising on, or checking advice on, pension transfers.

It is also worth noting that the exam standard for ApEx 21 has been amended to take account of developments in the pensions landscape following the introduction of the freedoms and the mandatory advice requirement, as well as the rules and guidance in PS18/6 and related consultation papers. The exam standard covers personal recommendations and advice boundary issues, appropriate pension transfer analysis (APTA) and transfer value comparator (TVC), overseas advice and taxation.

Firms are required to review employees’ competence on a regular and frequent basis and take appropriate action to ensure that staff remain competent for their role. This requirement should address any gap-filling issues arising out of the changes to the exam standard.