By Jonathan Laws, ACA Ch.FCSI — Senior Independent Financial Adviser, Cameron James
Key Takeaways
- Most people with a ReAssure pension did not buy it from ReAssure. It arrived there through an acquisition, and identifying the original provider is the fastest way to understand what your policy actually does.
- ReAssure is part of Phoenix Group, which has rebranded to Standard Life. Customers are being migrated onto Standard Life systems, so the position on what a policy permits is moving and should be confirmed at the time you make a decision rather than taken from an older article.
- Many ReAssure policies were written before the 2015 pension freedoms and were designed around annuity purchase. Flexible drawdown is not necessarily available within the policy terms, which for a non-UK resident is the practical constraint.
- Where drawdown is not available in the policy, the alternatives are usually an annuity, a lump sum, or a transfer. For someone living abroad with costs in another currency, the first two are often poor outcomes.
- ReAssure's book is legacy business, which is exactly where with-profits guarantees, guaranteed annuity rates and protected tax-free cash are found. These can be worth more than the flexibility a transfer would buy and must be established in writing first.
- For a non-UK resident, the permission that matters is the one required where you live, not UK authorisation. ReAssure provides factual information only and does not advise.
If you hold a ReAssure pension and you live outside the UK, you have probably already discovered that the options a UK resident takes for granted are not all open to you. ReAssure administers one of the largest books of legacy UK pension and life policies in existence, running to millions of policies acquired from other insurers over several decades. Those policies were written under the product designs, systems and assumptions of their time, and very few of them were built with a policyholder in Dubai, Sydney or Toronto in mind.
This guide starts somewhere unusual, with the question of which pension you actually have, because with ReAssure that is genuinely the first thing to establish. It then covers who owns ReAssure now, what your policy is likely to permit from abroad, the guarantees that a transfer could cost you, and the options open to you. It is not a case for transferring. On a legacy book like this one, the checks that come first matter more than the conclusion.
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Which Pension Did You Have Before It Became ReAssure?
ReAssure is a consolidator. It buys closed books of policies from other insurers, which means that for most policyholders the name on the annual statement is not the name on the original paperwork. If you are trying to work out what your policy does, the original provider is usually a better starting point than the current one, because the terms, the guarantees and the fund you are invested in all came from there.
On ReAssure's own published account of its history and of why it holds customers' policies, the blocks of business it has acquired include the following.
- Guardian Financial Services. Around 700,000 former Guardian policies were migrated onto ReAssure systems. Guardian itself traces back through Guardian Royal Exchange and had earlier been part of Aegon UK.
- Legal & General's mature savings business, agreed in 2017 and covering approximately 1.1 million policies, with the bulk of the transfer completing in 2020. If you had an older L&G savings or pension policy and the correspondence now comes from ReAssure, this is why.
- Old Mutual Wealth Life Assurance, previously Skandia, acquired from Quilter and completing at the end of 2019. Old Mutual Wealth Life Assurance became ReAssure Life Limited on 13 June 2020. Note that this is a separate legal entity from ReAssure Limited, which matters when you are sending Letters of Authority.
- The pension and annuity business of HSBC Life (UK), covering around 350,000 customers.
- Barclays Life, integrated by Part VII transfer.
- Alico UK, covering close to 300,000 policies.
- National Mutual, which had traded as Tomorrow.
- Windsor Life, which was itself rebranded as ReAssure. If your policy documents say Windsor Life, that is the same book.
- ReAssure also lists Zurich and GE among the insurers whose business it has taken on over the years.
Practically, this means two things. First, if you are searching for what happened to an old Guardian, Skandia, Windsor Life, National Mutual or Legal & General policy, ReAssure is very likely where it now sits, and you can ask them to check their records against your details. Second, when you come to review the policy, the questions you need answered are specific to the original product rather than to ReAssure as an administrator. A Skandia unit-linked pension and a National Mutual with-profits policy are entirely different propositions, even though both now carry the same brand on the statement.
What to look for on your paperwork
- The plan or policy name, which will often still carry the original provider's naming.
- Which legal entity administers it. ReAssure Limited and ReAssure Life Limited are different companies, and sending paperwork to the wrong one is a common cause of delay.
- Whether the policy is unit-linked or with-profits, and if with-profits, which fund.
- Any stated guaranteed benefit, guarantee date, guaranteed annuity rate, or protected tax-free cash entitlement.
- The selected retirement date, which on legacy policies is frequently still set to 60 or 65 and may be driving a lifestyling switch you did not ask for.
Who Owns ReAssure Now, and Why the Standard Life Migration Matters
ReAssure Limited is authorised by the Prudential Regulation Authority and regulated by the PRA and the Financial Conduct Authority, with FCA firm reference number 110495. Its regulatory standing is not in question and never has been.
The ownership chain is worth stating accurately, because it is often reported loosely. ReAssure was owned by Swiss Re's closed book business, Admin Re. Phoenix Group completed its acquisition of ReAssure Group plc in July 2020, making Phoenix the largest long-term savings and retirement business in the UK. Phoenix Group Holdings plc has since rebranded to Standard Life, moving its retail and workplace identity to that brand. So ReAssure sits within what is now the Standard Life group, but it arrived there via Phoenix, and Phoenix is the name that appears in the corporate history.
The reason this matters to you rather than being trivia is the migration. ReAssure customers are progressively being moved onto Standard Life systems and, in some cases, onto different product terms. Standard Life's open business does support flexi-access drawdown. That means the answer to “what can I do with this policy from abroad” is not fixed, and an article written eighteen months ago may describe a position that no longer holds. Confirm your own policy's current terms in writing at the point you are making a decision. Anyone who tells you flatly what ReAssure will and will not do, without reference to your specific policy and the current date, is guessing.
What Your ReAssure Policy Lets You Do From Abroad
The constraint on most ReAssure pensions is not that ReAssure refuses to deal with people overseas. It is that the policy itself was written before the options you now want existed.
A large proportion of the book dates from before 2010, and much of it predates the pension freedoms of April 2015. Those policies were designed on the assumption that you would accumulate a fund and then buy an annuity with it. Flexi-access drawdown, which lets you take income in whatever amount and at whatever frequency you choose while the rest stays invested, was not part of the design. Where it is not available within the policy terms, no amount of asking will produce it, because it is a product limitation rather than an administrative one.
Where drawdown is not available within your policy, the realistic options are usually these three:
- Buy an annuity. Available in principle, but UK insurers are often unwilling to write an annuity for someone resident overseas, and where they will, the income is in sterling and fixed for life. For someone whose costs are in euros, dirhams or Australian dollars, locking in a sterling income for thirty years is a significant currency bet.
- Take the fund as a lump sum. Simple, immediate, and usually the worst outcome for tax. See the next section.
- Transfer to an arrangement that does offer flexible access and is built for non-UK residents.
One further point on servicing. ReAssure is clear in its own documentation that it is not authorised to give advice or make personal recommendations, and can provide factual information only. That is entirely proper, but it means that when a non-UK resident calls to ask what they should do, the answer they get is a description of what the policy permits, with no view on what to do about it. Combined with restricted options, that leaves people stuck rather than informed.
The one email that saves the most time
Ask ReAssure in writing to confirm, for your specific policy number: whether flexi-access drawdown is available under the policy terms; whether partial withdrawals or UFPLS are available; whether benefits can be paid to a non-UK bank account and in what currency; whether the policy holds with-profits units and if so which fund and what the guarantee dates are; whether there is a guaranteed annuity rate; whether there is protected tax-free cash above 25 per cent; and whether there are any safeguarded benefits and their value. Everything else follows from those answers, and having them in writing means the review is done on facts rather than assumptions.
With-Profits, Guaranteed Annuity Rates and Protected Tax-Free Cash
This is the section that most often changes the conclusion. ReAssure's book is legacy business, and legacy business is precisely where valuable guarantees live. Establishing whether you have any is not a formality.
With-profits funds and market value reduction
ReAssure publishes the with-profits funds its customers are invested in, and names four: the LG With-Profits Fund, the Guardian Assurance With-Profits Fund, the Windsor Life With-Profit Fund and the National Mutual With-Profit Fund. ReAssure also notes that with-profits policies normally carry a minimum guaranteed value at certain points, such as maturity.
That last point is the one to focus on. If your policy has a guaranteed value at a stated date, leaving before that date can mean giving it up. A market value reduction may be applied on transfer or surrender, bringing the payout closer to the value of the underlying assets, and final or terminal bonus may not be paid on an early exit. Neither shows up on a standard valuation. You have to ask specifically, and you should ask for the guarantee date as well as the current deduction, because waiting a defined period is sometimes the right answer.
Guaranteed annuity rates
Older personal pensions and retirement annuity contracts, particularly those written before the late 1980s, sometimes carry a guaranteed annuity rate. Given the vintage of much of the ReAssure book, these turn up more often here than on a modern platform. A guaranteed rate set when interest rates were far higher can be worth considerably more than the open market equivalent today, and giving it up in exchange for flexibility is a decision that needs to be quantified. Occasionally the guarantee is worth keeping even at the cost of the flexibility, and a review that does not put numbers on that is not a review.
Protected tax-free cash
Some older schemes carry a right to tax-free cash above the standard 25 per cent, typically as a scheme-specific lump sum protection. It can be lost on transfer, or preserved only where the transfer is structured in a particular way. Where it exists it is worth preserving, and it is checkable in advance.
Safeguarded benefits above GBP 30,000
Where a policy provides safeguarded benefits, which includes guaranteed annuity rates and any defined benefit entitlement, and those benefits are worth more than GBP 30,000, the FCA requires advice from a pension transfer specialist before a transfer can proceed, irrespective of what the advice concludes.
Cameron James is not the pension transfer specialist in that process. That recommendation, and the liability attaching to it, sits with an FCA pension transfer specialist. Where a client has been through that process, we can assist on a case-by-case basis and subject to additional compliance steps with the receiving International SIPP, the investment strategy, the cross-border tax and reporting position and ongoing management. We do not present ourselves as facilitating a transfer against advice, and we would not encourage anyone to act against a negative recommendation.
Not sure what your ReAssure policy guarantees?
We will establish in writing what your specific policy permits and what it guarantees, and tell you plainly if the answer is to leave it where it is. No obligation and no charge for the initial review.
Why Taking the Whole Fund as Cash Is Usually the Worst Outcome
Where drawdown is not available and an annuity is not attractive, full encashment is the option people fall into by default. For a non-UK resident it is usually the most expensive route available.
The problem is concentration. Taking the whole fund crystallises all of it in a single tax year. Under UK rules up to 25 per cent can generally be taken as a pension commencement lump sum free of UK income tax, subject to the lump sum allowance of GBP 268,275. The remaining 75 per cent is taxable as UK income, and without the correct code in place it is likely to be taxed at source on an emergency basis, requiring a reclaim from HMRC afterwards.
The position in your country of residence is frequently worse, because most countries do not mirror the UK's treatment of the 25 per cent. From a local perspective the whole payment, including the part the UK treated as tax free, may simply be income. On a fund of a few hundred thousand pounds, taken in one year, that can push a large slice of it into the top local bracket. Spreading withdrawals across several tax years to stay within lower bands is exactly the planning that flexible drawdown makes possible and that a legacy policy without drawdown does not.
The specific outcome depends entirely on the double taxation agreement between the UK and where you live, on your other income, and on local rules for foreign pension income. It is not something to work out after the money has been paid.
Who Can Lawfully Advise You Where You Now Live
ReAssure does not advise, so any decision about the policy is either yours alone or comes from an adviser. For a non-UK resident, the permission that matters is the one required in the country where you are resident. Advice regulation follows the client, not the asset and not the adviser's home regulator. UK permissions do not, by themselves, carry a right to advise someone living in France, Spain, the UAE, Singapore, Australia or the US. Some UK advisers hold the relevant overseas authorisations. Many do not.
If you live in the EU or EEA
UK firms lost the ability to passport their permissions into the EU after Brexit. Ongoing investment advice to an EU-resident retail client now generally requires authorisation in that client's country of residence or an approved EU-level arrangement. Cameron James advisers hold individual EU authorisation in their own right, at individual adviser level, which is what allows the relationship to be properly constituted.
If you are a US citizen, green card holder or US tax resident
Advising a US-resident client on an investment portfolio generally requires SEC or state-level authorisation, and UK permissions do not satisfy it. Cameron James advisers hold individual SEC authorisation. We also do not charge an initial advice fee on US-connected pensions.
On reporting, investments held within a UK SIPP are not subject to PFIC reporting during accumulation, so the pension wrapper itself is not the reporting problem. PFIC becomes relevant for holdings outside a pension, such as in an ISA or a general investment account.
On the 25 per cent lump sum, our position, drawn from amalgamating the opinions of a number of third-party US tax advisers, is that it should not be assumed to be free of US tax. Taken as a single lump sum it is generally expected to be taxable in the US. There are arguments under the treaty for more favourable treatment where benefits are taken gradually over a longer period, for example through a sequence of UFPLS payments, but that is a planning question with a real range of professional opinion around it and it must be worked through with a CPA or Enrolled Agent before any crystallisation event. Our US-facing content sets out the analysis in full at cameronjamesusa.com. Background on our advisers' individual SEC authorisation is set out separately.
Your Options as a UK Expat or Non-UK Resident
Option 1: Keep the policy and fix the advice gap
If the policy holds a guarantee worth keeping, or a guarantee date worth waiting for, the right answer may be to leave it where it is and appoint an adviser who is authorised where you live to manage the wider picture around it. This is a real option and it is the one most articles on this subject skip past. It applies most often where there is a with-profits guarantee approaching, a guaranteed annuity rate, or protected tax-free cash.
Option 2: Transfer to an International SIPP
An International SIPP is a UK-registered, FCA-regulated pension scheme. It is not a different species of pension: it carries the same wrapper and the same UK tax treatment as any other UK SIPP. What differs is the infrastructure. It accepts non-UK addresses, pays income and lump sums to overseas accounts in local currency, supports full flexi-access drawdown for non-residents, handles NT code applications, and works through advisers holding the authorisations required where the client lives. Because both schemes are UK-registered, a transfer from ReAssure is a domestic UK transfer: no Overseas Transfer Charge, and no tax event on the transfer itself. The detail sits on our SIPP transfer page and the International SIPP pillar.
Option 3: A QROPS, in narrower circumstances than before
A QROPS moves the pension out of the UK altogether. The Overseas Transfer Charge applies 25 per cent to most such transfers unless the member is resident in the same country as the receiving scheme, and the Autumn Budget on 30 October 2024 removed the EEA and Gibraltar exclusion with immediate effect. The abolition of the Lifetime Allowance in April 2024 removed another historical driver. There remain cases where a QROPS is right, generally involving same-country residence and a specific treaty or succession reason, but it is now a tool for particular circumstances rather than a default.
How a ReAssure Transfer Works, and How Long It Takes
Where a transfer is the right answer, Cameron James runs the process end to end. On a legacy book, the sequence matters more than usual.
- Letters of Authority to the correct entity. Establish first whether the policy sits with ReAssure Limited or ReAssure Life Limited, because sending paperwork to the wrong one is a routine cause of delay.
- Full policy schedule and valuation, with specific written questions on with-profits units, guarantee dates, market value reduction, guaranteed annuity rates, protected tax-free cash and safeguarded benefits.
- Assessment of what a transfer gains and what it costs, on the numbers. If safeguarded benefits above GBP 30,000 are involved, this is the point at which a pension transfer specialist must be engaged.
- Establishing the receiving International SIPP and confirming it accepts your country of residence.
- Discharge paperwork and the transfer itself. Origo is available on some ReAssure business and not on all of it, and legacy books more often run on paper.
- MoneyHelper safeguarding appointment where the FCA's scam-prevention flags are triggered.
- NT code application to HMRC where the relevant double taxation agreement gives the taxing right on the pension income to your country of residence.
- Portfolio construction in the new structure, against your risk profile, time horizon, currency requirements and local tax position.
On timing, transfers from ReAssure generally take longer than from a modern platform. Six to twelve weeks from submission of complete paperwork is a reasonable expectation on straightforward unit-linked business. With-profits policies requiring a guarantee calculation, anything involving safeguarded benefits, and cases where a MoneyHelper appointment is triggered take longer, and it is sensible to plan on months. Starting well before you need income is the single most useful thing you can do.
How Cameron James Can Help
Cameron James specialises in cross-border pension and investment planning for UK nationals abroad and internationally mobile clients. Cameron James is FCA-regulated as a firm, and separately our advisers hold the individual authorisations required in the jurisdictions where our clients live, including individual SEC, CySEC and Gibraltar permissions. We are fee-based and take no commission from providers.
On a ReAssure policy specifically, that means identifying which entity holds it and which original provider it came from, getting the guarantee position confirmed in writing before anything else is decided, telling you honestly if the answer is to leave it alone or to wait for a guarantee date, and where a transfer is right, running it through to a properly structured portfolio and an NT code.
What This Means for You
If you hold a ReAssure pension and you live outside the UK, there is a genuine mismatch between a policy written for a UK resident retiring on an annuity and the life you are actually living. That mismatch will not resolve itself, and the closer you get to needing income, the fewer options you have.
But the mismatch does not automatically mean transfer. It means find out what you have. On a book of this vintage, some policies carry guarantees that outweigh the flexibility a transfer would buy, and the only way to know is to ask the specific questions and get the answers in writing. Do that while the pension is still in accumulation, well ahead of the point where you need the money, and you keep every option open. Leave it until you need income and the decision gets made for you.
Speak to an adviser about your ReAssure pension
We will identify what you hold, establish in writing what it permits and guarantees, and set out your options with no obligation.
Frequently Asked Questions
Phoenix Group completed its acquisition of ReAssure Group plc in July 2020. Phoenix Group Holdings plc has since rebranded to Standard Life, moving its retail and workplace identity to that brand, so ReAssure now sits within the Standard Life group. ReAssure Limited remains authorised by the Prudential Regulation Authority and regulated by the PRA and the FCA, with firm reference number 110495.
On ReAssure's own published record, the blocks of business it has acquired include Guardian Financial Services, Legal & General's mature savings business, Old Mutual Wealth Life Assurance (previously Skandia), the pension and annuity business of HSBC Life (UK), Barclays Life, Alico UK, National Mutual (which traded as Tomorrow) and Windsor Life, which was itself rebranded as ReAssure. ReAssure also lists Zurich and GE among insurers whose business it has taken on. Your annual statement will usually still carry naming from the original product, and ReAssure can check its records against your details.
It depends on your specific policy rather than on ReAssure as a whole. A large part of the book predates the 2015 pension freedoms and was designed around annuity purchase, so flexi-access drawdown is often not available within the policy terms. The picture is also changing as customers are migrated onto Standard Life systems. Ask ReAssure in writing to confirm, for your policy number, whether flexi-access drawdown and partial withdrawals are available and whether benefits can be paid to a non-UK account.
A market value reduction is a deduction applied when you leave a with-profits fund at a point other than a guarantee date, bringing the payout closer to the underlying asset value. ReAssure names four with-profits funds its customers are invested in: the LG, Guardian Assurance, Windsor Life and National Mutual with-profits funds. ReAssure also notes that with-profits policies normally carry a minimum guaranteed value at certain points such as maturity. Neither the deduction nor the guarantee date appears on a routine valuation, so ask for both specifically.
It is possible, and more likely here than on a modern platform because of the age of the book. Guaranteed annuity rates appear mainly on personal pensions and retirement annuity contracts written before the late 1980s, when interest rates were much higher. Where one exists it can be worth substantially more than the open market equivalent today, so it has to be valued before a transfer is considered rather than treated as a footnote.
No. Both are UK-registered pension schemes, so the transfer is a domestic UK transfer. It is not a benefit crystallisation event, no UK income tax arises, and the Overseas Transfer Charge does not apply because the pension is not leaving the UK. The treatment in your country of residence should still be confirmed with a local tax adviser.
You do if the policy provides safeguarded benefits, which includes guaranteed annuity rates and any defined benefit entitlement, worth more than GBP 30,000. In that case the FCA requires advice from a pension transfer specialist before the transfer can proceed, whatever that advice concludes. Cameron James is not the transfer specialist. Once that advice has been given we can assist with the receiving arrangement, the investments and the cross-border position on a case-by-case basis.
Longer than from a modern platform. Six to twelve weeks from submission of complete paperwork is reasonable on straightforward unit-linked business. With-profits policies requiring a guarantee calculation, safeguarded benefits cases, and transfers triggering a MoneyHelper safeguarding appointment take longer, and months rather than weeks is the sensible planning assumption. Establishing whether the policy sits with ReAssure Limited or ReAssure Life Limited before you start removes one common source of delay.
The advice position first: advising a US-resident client generally requires SEC or state-level authorisation, and UK permissions do not satisfy it. Cameron James advisers hold individual SEC authorisation, and we do not charge an initial advice fee on US-connected pensions. On reporting, investments inside a UK SIPP are not subject to PFIC reporting during accumulation, so the wrapper is not the problem; PFIC matters for holdings outside a pension. On the 25 per cent lump sum, do not assume it is free of US tax. Taken as a single lump sum it is generally expected to be taxable in the US, and while there are treaty arguments for better treatment where benefits are drawn gradually, that is a planning question to work through with a CPA or Enrolled Agent before any crystallisation.
Yes. ReAssure is clear in its own documentation that it is not authorised to give advice or make personal recommendations and can provide factual information only. That is the correct position for a product provider. It does mean, though, that you will get a description of what your policy permits and no view on what to do about it, which is why the review has to come from somewhere else.
Disclaimer
This article is for informational purposes only and does not constitute financial, tax or legal advice. Always consult a qualified and regulated financial adviser before making any decisions about your pension or financial planning arrangements. Tax laws are complex and vary by individual circumstance. Cameron James does not offer tax advice.
References to ReAssure and to the insurers whose books it has acquired are for identification purposes only and are drawn from publicly available regulatory and corporate sources, including ReAssure's own published material and the FCA Register, accessed at the time of writing. ReAssure Limited is authorised by the Prudential Regulation Authority and regulated by the PRA and the Financial Conduct Authority, firm reference number 110495, and sits within the group formerly known as Phoenix Group and now trading as Standard Life. Product and service terms are subject to change, particularly during the ongoing migration of customers onto Standard Life systems, and you should refer to ReAssure directly for the terms currently applicable to your specific policy.
Past performance is not a guide to future returns. The value of pension investments can fall as well as rise and you may get back less than you invest. Non-UK residents should be aware that UK pension rules interact with local tax law and reporting obligations in the country of residence, and independent tax advice in that country is essential before making any decision in relation to UK pension assets. For US-connected individuals this includes consideration of FBAR, FATCA, Form 8938 and the UK-US double taxation agreement.