What FCA CP26/20 means for SIPP due diligence

The FCA published CP26/20 on 22 June 2026, proposing new due diligence rules for SIPP operators alongside a Pension Scheme Money and Assets regime for scheme assets held outside the Client Assets Sourcebook. The consultation closed on 24 August 2026, with a Policy Statement and final Handbook changes expected in the first half of 2027.

The due diligence proposals set a tiered standard. Every SIPP investment would need core checks on non-taxable status, custody arrangements and valuation reliability, with enhanced checks on legitimacy and enforceability for higher risk assets. The new Pension Scheme Money and Assets regime, PSM&A under COBS 19B, would require operators to keep accurate records, verify holdings regularly, investigate discrepancies promptly and check how third parties process scheme data. The FCA has proposed a 12 month implementation window for due diligence and 24 months for PSM&A.

Industry reaction has been sharp. PIMFA has warned the rules could create unintended consequences for legacy and inherited book assets acquired through consolidation, where the acquiring firm inherits due diligence gaps it did not create. AJ Bell called the PSM&A regime a "sledgehammer to crack a nut", and noted that the FCA's own analysis accepts the rules could push some smaller or legacy heavy operators out of the SIPP market altogether.

What this means in practice.

For platforms and advisers selecting a SIPP administrator or custodian, due diligence and legacy book obligations belong in the selection criteria now, not after the Policy Statement lands. A provider's inherited book, its data lineage for legacy assets and its ability to evidence PSM&A style controls today are a better predictor of future compliance cost than its headline pricing. We have run SIPP and platform procurement processes end to end, from RFP and RFI design through supplier assessment frameworks, board audit notes and Heads of Terms negotiation, and we build due diligence into the evaluation criteria from the outset rather than treating it as a late stage check.

We bring deep, hands on experience of SIPP and platform procurement, including the RFP and RFI frameworks, supplier assessment tools and board ready due diligence documentation this kind of exercise needs. If CP26/20 touches your SIPP book or a live provider selection, get in touch and we can help you build due diligence into the process before the Policy Statement lands.