Project Overview
A UK FCA-authorised Self-Invested Personal Pension (SIPP) provider with 48,000 members and £2.1B AUM needed to...
Technology Stack
Compliance & Standards
The Challenge
A UK FCA-authorised Self-Invested Personal Pension (SIPP) provider with 48,000 members and £2.1B AUM needed to rebuild their legacy pension administration platform — replacing a 15-year-old .NET 3.5 application with a modern platform supporting pension aggregation (combining multiple pensions via Pension Dashboards API), flexible drawdown (Flexi-Access Drawdown), and HMRC pension reporting. FCA COBS 19 (pension advice and drawdown), FCA Consumer Duty (retirement income outcomes), Pension Dashboards Programme (PDP) API compliance, HMRC Real Time Pension reporting (RTPs), UK GDPR, and MiFID II suitability records were mandatory. Budget: £160,000.
Our Approach
Pension Dashboards Programme API Integration
- PDP (Pension Dashboards Programme): mandatory for large pension providers (FCA register >
- £100M AUM) — pension providers must make pension data available via the PDP ecosystem.
PDP data
- pension value (estimated retirement income, transfer value), benefit type (defined contribution, defined benefit), retirement date, and scheme details.
- ClickMasters integrates the PDP ISP (Identity Service Provider — verifying pension finder identity), PDP data response API (returning pension data in PDP standard JSON format), and PDP consent management (member consents to data sharing with their PDP app of choice).
- Flexi-
Access Drawdown Engine
Flexi-Access Drawdown (UFPLS — Uncrystallised Funds Pension Lump Sum): 25% tax-free, 75% taxed at marginal rate.
Drawdown calculation
fund value → tax-free cash entitlement calculation (25% of uncrystallised funds) → taxable income calculation → PAYE tax deduction (HMRC Real Time Pension reports — P45, P60, payroll via HMRC RTI).
Annual Allowance
platform tracks contributions against the £60,000 (2025) Annual Allowance — Money Purchase Annual Allowance (MPAA) trigger when drawdown income crystallises.
Annual Allowance breach alert
automated notification to member and IFA.
HMRC Real Time Pension Reporting
HMRC Real Time Information (RTI) for pension payments: pension income payments reported to HMRC on Full Payment Submission (FPS) on or before payment date.
HMRC Basic PAYE Tools or payroll software
SIPP platform integrates with HMRC PAYE RTI API directly — no third-party payroll software required.
P45
issued on first pension payment (if new to pension payments).
P60
annual summary issued by 31 May.
PAYE tax code
- HMRC returns tax code for each member via HMRC PAYE API — platform updates tax deduction automatically when HMRC issues a new code.
- FCA Consumer Duty —
FCA Consumer Duty PS22/9
SIPP providers must monitor retirement income outcomes.
Key metrics
- drawdown sustainability (members drawing at >
- 4% pa — sustainable drawdown rate monitoring), member understanding of drawdown risks (annual communication confirming understanding), and sequencing risk (drawdown in poor market conditions — platform flags members drawing >
- 5% pa in a down market year).
Annual Consumer Duty report
automated data from drawdown engine → QuickSight dashboard → Board Consumer Duty report (COBS 19 suitability review evidence).
The Results
FCA COBS 19 compliance confirmed.
PDP integration certified by PDP programme office.
Platform live at 22 weeks, £148,000 — under budget. 48,000 members migrated zero downtime.
PDP API: pension data available to Dashboard apps — first large SIPP to achieve PDP certification.
Drawdown processing time: 4.2 days → same-day automated.
HMRC RTI: 100% automated (previously 3 days per payment run).
Consumer Duty outcomes dashboard: Board approved first annual Consumer Duty report.
Member satisfaction: 4.4/5 (legacy platform: 2.0/5).
“First large SIPP to achieve PDP certification — our members can see their pension on any Pensions Dashboard app. Drawdown same-day versus 4.2 days. HMRC RTI 100% automated — 3 days per payment run returned to the team. Consumer Duty Board report produced from automated data. Member satisfaction from 2.0 to 4.4. The 15-year-old platform is gone and with it the risk it represented." — CEO, UK SIPP Provider (name withheld)”
Project Details
Related Case Studies
View AllOpen Banking AISP Platform for UK FinTech Startup
Open Banking AISP Platform for UK FinTech Startup. A UK FinTech startup needed to build an FCA-authorised Account Information Service Provider (AISP) platform that could a...
AI-Powered Customer Service Platform — UK FinTech
A UK FinTech company with 180,000 customers was spending £840,000/year on a 45-person customer service team, p...
Digital Banking Platform MVP — UK Challenger Bank
A UK challenger bank startup had received FCA authorisation with restriction (they could accept deposits but n...
Ready to Transform Your Business?
Let's discuss how our technical expertise can help you achieve remarkable results.