📋 Case Study Summary
- Client: “David,” aged 57
- Situation: Deferred DB pension from a pre-2006 employer scheme with a Protected Pension Age (PPA) of 50
- CETV offered: £345,000
- Current DC pot: £38,000 (separate employer)
- Goal: Access pension income earlier than age 57; weighing transfer options
- Outcome: Transfer NOT recommended — PPA protection too valuable to surrender
When most people think about pension transfers, they focus on the headline number — the Cash Equivalent Transfer Value (CETV). But sometimes the most important factor has nothing to do with money. This case study explores a situation where a single regulatory detail — a Protected Pension Age (PPA) — changed the entire advice picture.
Background: Who Is David?
David is 57 years old and works as a senior manager for a logistics company in the East Midlands. He has two pension pots:
- A deferred defined benefit (DB) pension from his former employer — a manufacturing firm he left in 2007. His normal retirement age under this scheme is 60, but the scheme rules were established before 6 April 2006, giving David a Protected Pension Age of 50.
- A defined contribution (DC) pension from his current employer, worth approximately £38,000.
David came to us having read about the pension freedoms and the ability to access his pensions from age 55 (now 57 under current rules). He was surprised to learn he might actually have access to his DB pension even earlier — but was also considering a transfer to a SIPP to take advantage of “more flexibility.”
Before 6 April 2006 (known as “A-Day”), many occupational pension schemes allowed members to take benefits from age 50. When pension legislation was overhauled in 2006, the minimum pension age was raised to 50 and then again to 55. However, individuals who had a right under their pre-2006 scheme rules to take benefits before age 55 can retain that earlier access date as a Protected Pension Age (PPA) — provided they meet certain conditions. This protection is personal to the member and, crucially, does not automatically transfer with the fund.
The CETV: A Generous-Looking Offer
David’s former employer had provided a CETV of £345,000. His DB scheme would pay:
- £14,200 per year from age 60, index-linked (CPI, capped at 2.5% per annum)
- A tax-free lump sum of approximately £42,600 (3x pension) on retirement
- A spouse’s pension of £7,100 per year on his death
On the face of it, the CETV of £345,000 was reasonable — the transfer value multiple (TVM) sat at around 24x the annual pension, broadly in line with prevailing gilt yields at the time of our review.
David had done his own research and concluded that a SIPP offering flexible drawdown, investment choice, and full pension freedoms access looked more attractive. He wanted to take some income at 58 and manage his own investments. His main question: should he transfer?
Step One: Understanding the Protected Pension Age
Before any financial modelling, we needed to establish the full picture of what David would be giving up — or keeping — on either path.
David’s scheme was established well before A-Day (6 April 2006), and the scheme rules at the time permitted members to take their benefits from age 50. David had joined the scheme in 1995 and left service in 2007. Under the transitional provisions in the Finance Act 2004, David retained a Protected Pension Age of 50 as a deferred member.
This meant David could — in theory — have already accessed this DB pension. He had chosen not to, because drawing at 50 would have applied significant early retirement reduction factors (the scheme reduced the pension by approximately 4% for each year taken before age 60).
HMRC rules make clear that a Protected Pension Age is not automatically carried over when benefits are transferred to a new scheme. If David transferred his £345,000 CETV to a SIPP, his SIPP would be governed by the standard minimum pension access age — currently 57 (rising to 58 in 2028 under planned legislation). His PPA of 50 would be lost permanently. This is not something that can be corrected after the fact.
The Modelling: Retaining the DB Scheme
We modelled three scenarios for David.
Scenario A: Retain DB, Draw at 60 (Scheme Normal Retirement Age)
- Annual pension from age 60: £14,200 (index-linked at up to 2.5% CPI)
- Tax-free lump sum at 60: £42,600
- Spouse’s pension on death: £7,100/year
- Break-even vs CETV (simple basis): approximately age 81–83, well within typical life expectancy
Scenario B: Retain DB, Draw Early at 58 (2 Years Early)
The scheme applied an actuarial reduction of approximately 4% per year before age 60. Drawing at 58 would reduce the annual pension to approximately £13,056/year — still index-linked and still with a spouse’s benefit. The early retirement reduction factor made early access less attractive financially but still viable.
Scenario C: Transfer to SIPP, Draw at 58
- CETV: £345,000 invested in a SIPP
- Assumed growth: 4.5% net of charges over 1 year (age 57 to 58)
- Projected pot at 58: approximately £360,500
- 25% tax-free cash: £90,125
- Remaining pot: ~£270,375 for drawdown
- Sustainable income at 3.5% drawdown rate: ~£9,463/year
- No guaranteed income; no spouse’s pension built-in; investment risk fully on David
- No protection against living longer than expected
The Critical Intangible: What Happens After 2028?
One additional dimension complicated David’s picture: planned changes to the minimum pension access age.
Under existing legislation, the normal minimum pension age (NMPA) is set to rise from 57 to 58 in 2028. Individuals with a PPA may be protected from this increase (subject to how the transition rules apply), but a fresh SIPP established by transfer would be subject to the new 58 threshold.
For David, the PPA of 50 — while he had chosen not to use it — provided considerable optionality. If his circumstances changed (health, redundancy, caring responsibilities), he could access income earlier than the general population. Surrendering that flexibility had a value that was difficult to quantify but very real.
The Recommendation
Following a full Transfer Value Analysis (TVAS) and an assessment of David’s attitude to risk, capacity for loss, and overall financial position, our recommendation was clear: do not transfer.
The key reasons were:
- Loss of Protected Pension Age: Irreversible and permanently removes a valuable flexibility option.
- Guaranteed income superiority: The DB income — even with early retirement reductions — significantly outperformed a sustainable SIPP drawdown rate on equivalent funds.
- Longevity protection: The DB pension pays for life, regardless of investment performance or how long David lives. A SIPP can run out.
- Spouse’s pension: David is married. The built-in £7,100/year spousal benefit is a meaningful protection that would require expensive annuity purchase to replicate.
- Index-linking: CPI-linked income (up to 2.5%) protects purchasing power in retirement. A drawdown pot requires active management and discipline to maintain real-terms value.
David’s £38,000 DC pension from his current employer was a different matter. This pot already sits within the flexible pension freedoms framework and gives David the access and flexibility he was seeking. Our recommendation was to continue contributing to this pot and — when the time came — use the DC pot for flexible drawdown while drawing the DB pension at or near age 60. This hybrid approach gave David the best of both worlds.
What David Decided
David agreed with the recommendation and decided to retain his DB pension. He also took the opportunity to review his DC pension fund choices, switching from a default lifestyle fund to a more growth-oriented multi-asset allocation given his 3-year time horizon.
He left the meeting with a clearer plan:
- Age 60: Draw DB pension at full rate (£14,200/year + £42,600 lump sum)
- Age 58–60: Supplement income with DC drawdown if needed (£38,000 growing to ~£42,000)
- State pension: Expected from age 67 — an additional layer of guaranteed income
Key Lessons From This Case Study
1. The CETV Is Only Part of the Story
A CETV of £345,000 sounds like a lot of money. But without understanding what you’re giving up — guaranteed income, spouse’s pension, index-linking, and in David’s case a Protected Pension Age — the number alone tells you very little.
2. PPA Is a Rare and Valuable Right
Protected Pension Ages are relatively uncommon — they’re restricted to members of pre-A-Day schemes who had a contractual right to early retirement. If you think you might have one, it’s worth checking your scheme’s rules carefully and taking specialist advice before making any transfer decisions.
3. Flexibility Has a Cost
Pension freedoms and SIPP flexibility are genuinely valuable features. But they come with investment risk, sequencing risk, and longevity risk. For many people — particularly those with meaningful DB entitlements — the certainty of a guaranteed income outweighs the flexibility of a SIPP.
4. The Hybrid Approach Often Works Best
Where clients have both DB and DC pensions, a hybrid strategy — drawing each at different times and for different purposes — often produces better outcomes than converting everything into one vehicle. DB for the floor; DC for the flexibility.
📋 Frequently Asked Questions
Q: Can I transfer a DB pension with a Protected Pension Age to a SIPP?
A: Yes, technically you can — but you will permanently lose the Protected Pension Age protection. The receiving SIPP will be subject to the standard minimum pension access age rules (currently 57, rising to 58 in 2028). This is a significant consideration and should be weighed carefully before proceeding.
Q: How do I find out if I have a Protected Pension Age?
A: You would need to review the original scheme rules for any DB pension you held before 6 April 2006, or contact the scheme trustees directly to ask whether a PPA applies to your benefits. Your pension statement may also indicate an early retirement age.
Q: What are the early retirement reduction factors on a DB pension?
A: These vary by scheme, but many apply an actuarial reduction of 3–5% per year for each year you draw before the scheme’s Normal Retirement Age. Some schemes have more generous early retirement terms, particularly for long-serving members — always check your specific scheme rules.
Q: Is a DB pension always worth keeping over a SIPP?
A: Not necessarily. There are circumstances where a transfer can be appropriate — for example, those with poor health and no dependants, or those with very large pensions where flexibility and IHT planning are priorities. However, the FCA requires that a transfer specialist recommends against transfer unless there are clear reasons in the client’s specific circumstances to do otherwise.
Seeking Professional Advice
The situation described in this hypothetical case study illustrates how complex pension transfer decisions can be — and why specialist regulated advice is so important. A Protected Pension Age is an unusual feature that many people don’t know they have, and surrendering it through a transfer would be an irreversible mistake.
If you have a deferred DB pension — particularly one from an employer you left before 2006 — it is worth checking whether a Protected Pension Age applies to your benefits. A qualified pension transfer specialist can review your scheme documentation, model the options, and help you understand the full picture before making any decisions.
This case study is a hypothetical example for illustrative purposes only. All figures are illustrative. The outcome described reflects a specific set of circumstances and does not constitute financial advice. Individual outcomes will vary.
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