Resources & Insights

Neil Robbirt on Raising Standards in Expat Pension Advice

By QROP Direct Editorial Team · Interview with Neil Robbirt, Chairman of Global Investments Group · Reviewed 2026-06-16

Neil Robbirt on Raising Standards in Expat Pension Advice

The following is an interview with Neil Robbirt, Chairman of Global Investments Group. His views are provided for general education and information only and are not personal financial, tax or legal advice. Pension rules depend on your individual circumstances and country of residence and can change. Always take regulated advice in the relevant jurisdiction before acting.

QROP Direct: You've spoken publicly about standards in the expat pension advice market. How would you describe the state of that market today?

Considerably better than it was a decade ago, but still uneven. The regulatory intervention around defined benefit transfers in 2018 and 2019 changed behaviour in the UK market for the better — it forced a much higher bar on suitability and made advisers think hard before recommending a transfer. That was overdue and it worked.

The difficulty in the international space is that an expat is often dealing with advisers who sit outside the FCA's perimeter, in jurisdictions where the rules and the enforcement are not as consistent. So you still have a long tail of operators whose standards would not survive scrutiny in a well-regulated market. My consistent position is that the benchmark for acceptable advice has to keep rising: not just technically compliant, but genuinely in the client's interest and properly calibrated to the cross-border situation the client is actually in.

QROP Direct: What does "genuinely in the client's interest" mean in practice?

It means starting from the client's whole picture rather than from a product. A UK expat's pension sits inside a web of decisions — tax residency, double taxation agreements, currency exposure, estate planning, when and whether they intend to return to the UK. Good advice begins by understanding all of that. Poor advice begins with a product that the adviser is keen to sell and works backwards.

The clearest tell is what happens when the right answer is "do nothing." A good adviser will frequently tell a client not to transfer, not to move, not to act — because leaving a defined benefit pension where it is, or keeping funds in a UK SIPP, is often the better outcome. An adviser who only ever recommends action is not advising; they're selling.

QROP Direct: How can an expat who isn't an expert protect themselves when choosing an adviser?

Three practical checks. First, how is the adviser paid? You want a clear fee that you agree in advance and pay directly, not a commission buried inside a product. Commission creates an incentive to recommend the product that pays, and that incentive does not always point towards your interests.

Second, qualifications and permissions. For any defined benefit transfer the adviser must hold the pension transfer specialist qualification — AF7 or its equivalent — and the appropriate regulatory permissions. Ask to see them. A credible adviser will be entirely comfortable with that question.

Third, relevant international experience. UK pension knowledge alone is not enough. You need someone who understands the tax rules of your specific country of residence and how the UK's double taxation agreement with that country actually works in practice. Generic advice applied to a specific jurisdiction is where a lot of damage is done.

QROP Direct: You've emphasised long-term relationships over transactional advice. Why does that distinction matter so much?

Because a pension plan is not a single decision; it's a sequence of decisions over decades, and circumstances change. People move country, the rules change, markets move, families grow, intentions about returning to the UK shift. A plan that was right at the point of advice can drift badly out of alignment within a few years.

Many of the worst outcomes we have encountered across Global Investments Group's work have come from one-off advice: someone arranged a transfer or a product, took their fee, and moved on. There was nobody watching when the client's situation changed — when they moved to a country where an exemption no longer applied, or when a rule change altered the tax treatment of what they'd done. A genuine long-term advisory relationship, where the adviser knows the client and reviews the plan as life evolves, is a qualitatively different standard of service. It is the model Global Investments Group has always argued for and built its practice around.

QROP Direct: Where does the industry still have the furthest to go?

In handling complexity honestly. The expat-specific complications — the Overseas Transfer Charge rules since the 2024 change, the way double taxation agreements interact with pension income, the MPAA implications of accessing a pension flexibly while abroad — are genuinely difficult, and they are precisely the areas where clients are most exposed to irreversible mistakes.

Too often that complexity is either glossed over because it's inconvenient to explain, or used to intimidate the client into deferring entirely to the adviser. Neither is acceptable. The standard we should hold is that the complexity is understood by the adviser and then clearly communicated to the client, so the client can make an informed decision. That's the difference between advice that empowers and advice that simply extracts a fee.

QROP Direct: What would you say to an expat who suspects they may have had poor advice in the past?

Get a second opinion from a genuinely independent, qualified adviser — and do it sooner rather than later. Some mistakes can still be mitigated if they're caught early; others cannot be undone but can at least be managed from here. The instinct to avoid looking at a decision you fear was wrong is understandable, but it's the most expensive instinct there is. Daylight and a qualified second opinion are almost always worth it.

The Context Behind the Conversation

The following analysis is provided by the QROP Direct Editorial Team as background to the interview. It is general information, not personal advice.

The "regulatory intervention of 2018–2019" referred to in the interview has a concrete shape that is worth setting out. The FCA's Consultation Paper CP17/16 and the policy statements that followed tightened defined benefit transfer advice on several fronts at once: the APTA methodology replaced looser comparison approaches, advice was required to start from a presumption that retaining the DB pension is the right answer, and qualification requirements for pension transfer specialists were enhanced. Even so, the FCA's review of DB transfer advice quality in 2021–22 found that a significant minority of firms had given unsuitable advice, and enforcement actions and firm closures followed. The net result has been a smaller, better-regulated advice market — and transfer volumes substantially below the 2016–2019 peak.

That history explains why "do nothing" features so prominently in the conversation above. Under the current framework, the vast majority of defined benefit cases end in a recommendation to retain: a healthy member with a normal life expectancy, a spouse, and no unusual tax position will almost always keep more lifetime value in the scheme than a transfer would deliver. An adviser whose recommendations run consistently the other way is out of step with how the regulated market actually behaves — which is precisely the warning sign the interview describes.

The Legal Floor Beneath the Standards

Everything above concerns the quality of advice. Beneath it sits a legal floor that applies wherever in the world the member lives: for any defined benefit pension valued above £30,000, UK law requires that regulated advice from an FCA-authorised firm — involving a pension transfer specialist — is taken and evidenced before a transfer can proceed. The ceding scheme will ask for a copy of the advice before releasing the transfer. No offshore arrangement and no adviser outside the UK's regulatory perimeter can waive that requirement, and any arrangement that claims to sidestep it is itself a warning sign. For expats, this floor is the practical starting point for the checks discussed in the interview: an adviser who is vague about it has failed the first test before any conversation about fees or qualifications begins.

Summary: Recognising Good Expat Pension Advice

The themes from this interview, in order of priority:

1. Whole-picture first — good advice starts from your circumstances, not a product
2. "Do nothing" is a valid answer — be wary of an adviser who only ever recommends action
3. Check how the adviser is paid — a clear, agreed fee, not hidden commission
4. Verify qualifications — AF7 (or equivalent) and the right permissions for DB transfers
5. Insist on jurisdiction-specific experience — UK knowledge alone is not enough
6. Favour a long-term relationship over one-off, transactional advice
7. If in doubt about past advice, get an independent second opinion early