Phoenix Life Limited trading as Standard Life · DRN-5967323

The complaint Mr A has complained about the lack of transparency shown by Phoenix Life Limited trading as Standard Life (Standard Life) because it has not provided him with a full, itemised, year- by-year breakdown of all annual management charges, fees, and adviser/commission costs applied to his plan from its inception in 2003 to 2021. What happened The history leading up to this complaint is well known to the parties and has been clearly set out in the investigator’s assessment which he provided to both parties, therefore I have only summarised events below. In December 2024 Mr A requested information about the charges applicable to his pension plan. Specifically, Mr A sought details of the charges on his plan in monetary terms from the start date on 1 July 2003. Standard Life responded that it only had details of the charges in monetary terms from 2021, when it became a requirement to include this on annual statements. Standard Life provided Mr A with details of the charges from 2021 to 2024 and the level of fund management charge and the discount that applied to his plan. Mr A requested further information about his plan and there was substantial subsequent correspondence between the parties throughout May 2025, with Mr A continuing to ask for the charges information to be provided in monetary terms. He also explained that he found the information provided via his online account to be quite technical and difficult to fully understand and requested a year-by-year breakdown of charges to be provided in a simpler format. Ultimately, Standard Life spoke to Mr A by phone on 29 May 2025. Notes for this call indicate Mr A was intending to consolidate his plans and required information about his Standard Life plan. He wanted to compare the charges with another provider. Standard Life explained its charging structure and provided general information about the plan. On 5 June 2025, Standard Life wrote to Mr A to explain that it was unable to provide him with the details of the charges on his plan in monetary terms since it commenced in July 2003. It did provide figures for 2022, 2023 and 2024 and explained that it was only from 2022 that it was required to provide details of the charges in the terms he had requested. And it told Mr A once again that it couldn’t provide historic charges. Unhappy with this response, Mr A complained to Standard Life on 8 June 2025. Standard Life didn’t uphold the complaint stating it had provided Mr A with all the information it was able to and it had not made any error. It explained that it had no obligation nor was it a legal requirement to provide a monetary figure for charges prior to 2022. It acknowledged that the reason Mr A required historical information on charges in a monetary format was to compare charges with other providers (Mr A was considering consolidating his pensions plans). However, it explained that unless the other providers had similar charging structures, using this method wouldn’t be able to be used as a comparison. It went on to provide details of the fund charge applicable to Mr A, which was based on his fund value and expressed as a percentage. And it provided the charges in monetary terms

-- 1 of 4 --

for Mr A’s policy from 2022 to 2025 inclusive. It also provided his plan value from 30 June 2004 to 20 June 2021. On 16 July 2025, Mr A emailed Standard Life in reply to its final response. He acknowledged the efforts of Standard Life in providing yearly plan values for his pension since 2004 and the monetary breakdown of charges from 2022 onwards. Whilst he understood that formal regulatory requirements have changed, he expressed disappointment that it was unable to provide a historic breakdown of the charges prior to 2021 and requested final clarification as to whether Standard Life could provide historical charges in monetary terms or at least, be able to estimate these based on its records. Standard Life responded the next day as follows: This is not an unwillingness to provide you with information, we are unable to do so. I have provided you with the plan values for 22 years on the annual statements dates so you can estimate the charges based on the fund value. For example, 1% fund charge on £20k is £200 in monetary terms. I cannot confirm the fund charge remained constant since inception, I am very sorry but the historical fund data we hold does not confirm the total expense ratio as far back as 2003, only the underlying management charge which was constant at 1% There was subsequent correspondence, but Standard Life’s position remained unchanged. So, on 26 July 2025, Mr A referred his complaint to this Service for an independent assessment. Two days later, Standard Life provided Mr A with updated plan information and transaction statement from 29 July 2003 to 28 July 2025. Separately, it confirmed once again that it does not hold the historical data needed to accurately calculate the charges as Mr A requested, and there was no legal requirement to do so prior to 2022. Standard Life said it had provided Mr A with enough information for his current planning, including the charge rates and plan values over time, to enable him to do a rough calculation of the charges incurred pre-2022. One of our investigators looked into Mr A’s complaint but didn’t think that it should be upheld. He reasoned that Standard Life are not at fault for not having the information needed to provide Mr A with the information he’s requested about all of his plan charges since its inception. This is because until February 2021 there was no requirement for providers to provide such information to its customers. He concluded that Standard Life supplied Mr A with as much information as it could, to enable him to carry out a rough calculation of the historic charges pre 2022 and said this is what we would expect in the circumstances. Mr A didn’t agree and so his complaint has been referred to me for a final decision. What I’ve decided – and why I’ve considered all the available evidence and arguments to decide what’s fair and reasonable in the circumstances of this complaint. It’s clear to me that Mr A has strong feelings about this complaint. He has provided detailed arguments to support his case which I can confirm I’ve read and carefully considered. However, I trust he will not take the fact that my findings focus on what I consider to be the central issues, as a discourtesy. The Financial Ombudsman Service was set up to be a quick and informal alternative to the courts. And the purpose of this decision is to explain what I think is fair and reasonable in the circumstances, not to offer a point-by-point response to everything the parties to the complaint have said.

-- 2 of 4 --

So, I will not refer to every submission, comment, or argument. Instead, my decision sets out what I think are the most important points in order to explain my decision in a way that is intended to be clear and easy to understand. Additionally, the Financial Ombudsman Service is not a regulator. This service’s role is to deal with individual complaints and determine whether a firm has done anything wrong pertaining to a particular complainant. If we find it has, we’ll then go on to consider whether a complainant has suffered any financial loss or inconvenience as a result of a firm’s conduct. We cannot require a firm to change its practices; that is the role of the regulator. But we can highlight in an individual case how a practice may have impacted on a particular consumer’s loss or inconvenience. My remit is to consider what’s fair and reasonable in all the circumstances of this complaint. In doing so I am required to have regard to (amongst other things) relevant rules and regulations, as well as good industry practice. While I understand Mr A’s frustration here, I don’t think Standard Life has been unreasonable or treated him unfairly, so I am not upholding his complaint. I will explain why. The regulator, the Financial Conduct Authority (FCA), sets down the rules which firms must follow where they are carrying out financial services, as Standard Life was in Mr A’s case. These are contained in the FCA’s Conduct of Business Sourcebook (COBS). Mr A is invested in the Standard Life Managed Pension Fund. This is a fund of funds which is when one fund invests in other funds that operate across various markets. This is a common approach for pension investments. It spreads the investment risk across a wide range of investments and markets. As the fund manager actively buys and sells investments held within a fund there are transaction costs involved in these trades. These are commonly referred to as an annual management charge (AMC) or fund management charge (FMC). Every fund from every fund manager has this cost, though the rate may vary. When Mr A’s plan started in 2003, he would have been provided with the terms and conditions of the plan, which included details of the charges that applied to his arrangement. This explained that Mr A’s plan has an FMC which is applied to the money invested in Standard Life funds. But the FMC is not a set fee deducted separately each month. Instead, the charge is deducted from each fund daily and this has the effect of reducing the fund’s unit price. As the pension provider, Standard Life are obligated to provide its customers with information to allow them to make informed choices. The information and level of detail the FCA has required be provided has changed over time. So, in annual statements provided to Mr A from 2004 to 2021, these charges were expressed as a percentage but did not explain them in monetary terms. This satisfied the regulatory requirement at the time. As such, Standard Life did not retain information on the daily unit price adjustments and resulting monetary amount. In February 2021, the FCA amended COBS and introduced a new requirement set out in COBS 16.6.10R. The purpose of this change was to provide consumers with greater insight into the costs of financial products. In summary, COBS 16.6.10R requires firms to provide annual statements which include costs and charges information which must, among other things, be expressed in pounds and pence going forward. And now providers like Standard Life have systems in place to meet this requirement.

-- 3 of 4 --

I can see that the charges information Mr A has been provided since this requirement came into effect does detail the total charges taken from the pension in monetary terms. But Mr A would like for Standard Life to recreate this for his plan covering the 18 years before this was a requirement. Standard Life have explained it does not have the information needed to do this. The requirements of COBS 16.6.10R are not retrospective, so I don’t think it unreasonable that Standard Life is not able to produce the historic charges information Mr A seeks. In response to the investigator’s view, Mr A raised the SYSC record keeping requirements and argues that Standard Life are not meeting these requirements. But he has not explained which part of SYSC he refers or how Standard Life has breached these requirements. Regardless, as explained, this service is not the industry regulator. Where matters, and evidence of, regulatory breaches are directly relevant to determining a complaint, they can be considered for that particular purpose, but not for the isolated purpose of holding a firm accountable for a regulator breach. It is the regulator’s remit, not ours, to investigate allegations about firms breaching its rules and regulations, and if proven, to hold them accountable for that breach. In the circumstances presented here, I am satisfied Standard Life has provided Mr A with a variety of information that would enable him to determine an estimate of charges in monetary terms for the years prior to 2021. The historic information needed for a more exact calculation is difficult, if not impossible to provide. This doesn’t suggest that Standard Life is in some way negligent in the information it retained and can now provide. It is simply a reflection of the regulations and market’s practices at that time. As such I do not believe there is any further historic information that Standard Life can reasonably be expected to provide to Mr A regarding the charges levied on his pension from inception until 2021. Additionally, I note that Mr A wants this information as he is looking to consolidate his pensions, but I don’t see how the historic values are necessary to this determination. Mr A also said he wants to ensure that he has been charged correctly throughout the life of his plan. But he has not asserted that Standard Life has done something wrong regarding the charges that have been applied to his pension plan. If this is his concern, this will need to be raised with Standard Life in the first instance. I know that this will come as a disappointment to Mr A, but I am not persuaded that Standard Life has done anything wrong, so I am not upholding this complaint. My final decision For the reasons I have set out above, I do not uphold this complaint. Under the rules of the Financial Ombudsman Service, I’m required to ask Mr A to accept or reject my decision before 23 April 2026. Jennifer Wood Ombudsman

-- 4 of 4 --