Complex Hartley Pensions administration continues amid 'misappropriated funds' investigation

Administration expected to conclude in 2027

Isabel Baxter
clock • 3 min read
Complex Hartley Pensions administration continues amid 'misappropriated funds' investigation

The investigation into failed Hartley Pensions is ongoing but slower than originally expected due to its complexity and scale, with the joint administrators noting delays related to potentially ‘misappropriated funds’.

The latest administrators report from joint administrators Brian Johnson and Peter Kubik of UHY Hacker Young gave an update on how many clients have been transferred out of the failed providers' self-invested personal pension (SIPP).

Broken down, according to the latest administrators report, this included:

  • All RL360 clients. There were 905 RL360 clients involved in the Hartley case according to UHY Hacker Young's website.
  • Ardan & Trireme clients: 257 transferred out of 340
  • Fundment clients: 172 transferred out of 240
  • Platform One clients: 295 transferred out of 391
  • Clients with an asset value of less than £10,000: 54 out of 130 clients. The report stated that 12 transfers are in process and 64 clients have not responded.

For the following groups, transfers are ongoing or not fully quantified in the document: James Brearley / Octopus; Simply Ethical; deceased clients; standard assets; opt-outs; and impaired assets.

These clients are among the 16,000 to 17,000 who were affected by the collapse of Hartley Pensions.

This report covered progress from 29 July 2025 to 28 January 2026.

According to a separate UHY Hacker Young update dated 3 October 2025, 6,000 SIPP clients had at the time been contacted, of which 2,636 have been transferred.

Ongoing investigations

The administrators report also highlighted significant operational and regulatory matters related to Hartley Pensions that remain under investigation, some of which are now publicly linked to court proceedings.

Wilton UK (Group) bought Hartley Pensions in 2016 and is wholly owned by Wilton Group in the Isle of Man.

Before Hartley Pensions went into administration, it was found that around £37m was withdrawn from 1,320 client accounts and transferred into the Wilton Group.

The director claimed all funds were returned to clients, but as of the report's publication this could not be verified, the administrators reported stated.

It stated that tracing is ongoing to determine if any client monies remain in related entities, including Orex Consultancy, General Consolidated, General Subsidiary 2, and Guinness Mahon.

The joint administrators set out that the investigation into the misappropriated funds continues "to be hindered" by two key factors:

·       Funds were moved outside the Hartley Pensions' control into other Wilton group entities, limiting the joint administrators' access.

·       FSCS compensation cannot currently be applied to the investigative work stream.

Extension of Hartley administration until 2027

Hartley Pensions went into administration on 29 July 2022 at the request of the Financial Conduct Authority and was placed under investigation by the Financial Services Compensation Scheme (FSCS).

The FSCS previously said it would not pay the charges, but decided on 29 January that it would pay the exit and administration charge after it "obtained and considered further evidence". It previously said the charges were outside the scope of its rules.

Hartley Pensions was declared in default by the lifeboat fund on 21 February 2024 following its investigation.

The administration of Hartley Pensions has been extended multiple times.

An initial 12-month extension was approved by creditors on 4 July 2023, moving the expiry to 28 July 2024.

As that date approached, the court granted a further 18-month extension on 23 July 2024, extending the administration to 28 January 2026.

A subsequent application on 17 December 2025 led to another 18-month extension granted on 16 January 2026, meaning the administration is now expected to end on 28 July 2027.

The Hartley SIPP investigation has been ongoing for several years and clients have faced months-long SIPP transfer document delays.

In August 2024, PA learnt that some clients were yet to receive their Hartley Pensions SIPP documents after it was promised that communications would be issued from April through to June.

Read more on Hartley Pensions: Failed Hartley Pensions clients face months-long SIPP transfer document delays

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