Article Summary

By Jonathan Laws, ACA, Ch.FCSI, Senior Independent Financial Adviser, Cameron James USA.

If you live in the United States and hold a UK pension, you have probably already discovered that most UK SIPP providers will not deal with you. Some never accepted non-UK residents in the first place. Others accepted them years ago and have since withdrawn, in several cases writing to existing clients and giving them a deadline to move. We have covered that pattern as it has happened, including Interactive Investor, Vanguard and Bestinvest.

The list of UK SIPP structures that will genuinely accommodate a US-resident member, and that can be operated lawfully once your money is inside, is short. This article sets out who is on that list, how the structures differ, and the one point that catches most expats out: there is no compliant way for a US resident to run one of these pensions on a self-invest basis.

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Key Takeaways

  • Novia Global and Morningstar Wealth International are the two integrated options. The SIPP and the investment platform come from the same provider, so no separate investment vehicle is required.
  • iPensions Group and IFGL are non-integrated on their adviser propositions. They provide the pension wrapper, and a platform or other investment vehicle has to be appointed alongside it.
  • Accepting a US-resident member is only the first test. The second is whether the investments inside the wrapper can be selected, dealt and advised on lawfully.
  • Self-investing is not a compliant route for a US resident. The providers do not offer execution-only access to US-resident members, and the reason is regulatory rather than commercial.
  • The compliant structure is a UK-registered SIPP advised by an adviser holding US authorization. Cameron James USA advisers hold individual SEC authorization.
  • Costs vary widely. On the published schedules we have seen, the integrated options land around 0.4 to 0.5 percent a year at mid-size pension values before fund and adviser charges. The non-integrated options cannot be totalled until the second contract is quoted.
  • Our advice fee for UK pension transfers is a hybrid fixed fee rather than an open-ended percentage.

Why the List Is So Short

A UK SIPP is a UK-registered pension scheme. Nothing about your move to the United States changes that. What changes is who is allowed to deal with you.

Once you are resident in the United States, a UK platform that takes investment instructions from you is dealing with a retail client located in the US. A UK adviser who recommends investments to you is advising a US person on securities. Both activities sit inside the US regulatory perimeter, and neither is something a UK-only firm can do simply because the underlying pension happens to be British. The exemptions available to a firm with no US registration are narrow, and the SEC sets them out in its adopting release on exemptions from investment adviser registration.

Most UK providers have looked at that and concluded it is not worth the compliance burden. They close the door, either to all non-UK residents or to US residents specifically. A small number have built a proposition that works, on the condition that a properly authorized adviser sits in the middle.

The Two Tests a Provider Has to Pass

It is worth separating two questions that often get merged into one.

Test one: will the scheme accept a US-resident member?

This is a policy question and the answer is usually a straight yes or no. It is also the easier test, and the one most comparison articles stop at.

Test two: can the money be invested and advised on lawfully once it is in there?

This is the harder test and the one that matters more. A provider can happily accept your application and still leave you with a structure that cannot be run properly, because the investment side has not been solved. That is where the integrated and non-integrated distinction comes in, and it is where the self-invest question gets answered.

Integrated Providers: the SIPP and the Platform in One

Novia Global

Novia Global is the provider we have worked with longest, and it remains the most commonly used International SIPP for cross-border clients. It is a UK-registered SIPP administered by Novia Global Limited, authorized and regulated in the UK, and accessed through the Novia Global investment platform. The SIPP and the platform are the same proposition, so there is no second contract to arrange.

For US-connected clients the SIPP does accept US persons. One distinction is worth getting right, because it is easy to misread. The Novia Global General Investment Account cannot be used on a standalone basis by a US resident. Held inside the SIPP, it can. In other words the constraint attaches to the General Investment Account as a wrapper in its own right, not to its use as the investment account within the pension, which is how it is most commonly used for our US clients. Access is also not open to every adviser: the SIPP requires a formal adviser relationship and specific onboarding, which is one reason the same handful of firms appear repeatedly in this market. We cover the adviser-led design in our article on whether you can self-invest a Novia Global SIPP.

Morningstar Wealth International

The Morningstar International SIPP, previously the Praemium International SIPP, is administered through the Morningstar Wealth International platform. Like Novia Global it is an integrated proposition: the platform holds the assets, processes contributions and withdrawals, and handles the administration and reporting attached to a UK SIPP.

It is explicitly adviser-led. That is a design feature rather than a restriction, and it is the reason it works for cross-border clients at all. The platform operates a tiered custody and administration charge applied per account and billed monthly in arrears, with a low per-trade transaction charge and, on the schedule we have seen, no setup, exit or re-registration fees. Costs are straightforward to model, which matters when you are comparing structures over a twenty or thirty year horizon.

For a US-audience reader there is one feature that sets it apart from everything else on this list. Morningstar operates a dedicated service tier for retail clients who are US taxpayers. It restricts investment management to SEC-regulated managers, provides reporting aligned to IRS requirements, and carries its own tiered platform charges plus an annual US tax report fee. Access to US-domiciled funds through that route is a material advantage over platforms that were never built for this client profile.

Non-Integrated Providers: the SIPP Is Only Half the Structure

The next two providers are frequently listed alongside Novia Global and Morningstar as though they were equivalent. They are not, and the difference is structural rather than a matter of quality. These are pension wrappers. They do not come with an investment platform attached, so a separate investment vehicle has to be appointed inside the SIPP before a penny can be invested.

That is not automatically a bad thing. It can give you more freedom over where the assets sit. But it means two sets of terms, two fee schedules and two counterparties, and it means the question of whether the investment side is compliant for a US resident has to be answered separately from the question of whether the SIPP will take you.

iPensions Group

iPensions Group, rebranded from Momentum in 2020, publishes several SIPPs. The range narrows sharply once you are a US resident. The Platform SIPP, which has investment access built in, is not available to you. Neither is any self-invest option. What remains is a dedicated adviser-led product for US residents with its own terms and fee schedule. Our full review is here.

That is worth pausing on, because it is this whole article in miniature. iPensions has an integrated product on the shelf and a self-directed route alongside it. It withholds both from US residents and offers only the advised, non-integrated version. Providers do not build a separate US product and hand back the easier business for no reason.

That product is a pension wrapper and nothing more. The annual trust fee covers one appointed investment platform, with a charge for each additional provider and a further charge to change provider, so the structure assumes a single platform sitting inside it, selected by your adviser.

IFGL

IFGL provides the pension trustee and administration function, with the investments held on a separately appointed platform. The structure works, but there is one feature we would want any prospective member to understand before signing: the wrapper-level cash retention. The published terms require a minimum cash balance expressed as a percentage of plan value, subject to a floor and a ceiling, held on an ongoing basis so that charges can be deducted. On a mid-size transfer that means a portion of your money is in cash from day one, permanently, and it is most visible for clients in accumulation who are neither contributing nor drawing income. Layered on top of the SIPP fee, the platform fee, fund charges and adviser fees, it is a cost that is rarely shown to clients on a single page. Our full review is here.

We regard that as one of the weaker structural features of the IFGL SIPP and a meaningful point of difference against the integrated alternatives, none of which operate an equivalent retention at wrapper level.

In fairness, cash carries a cost everywhere. Novia Global does not impose a minimum balance, but on the schedule we have seen it does not pay interest on client cash either, and retains the margin it earns on it. That is disclosed openly. The practical lesson is the same in every case: cash inside a pension wrapper is rarely free, so hold no more of it than the plan requires.

At a Glance

ProviderStructureSeparate vehicle needed?Key point for US residents
Novia GlobalIntegrated. UK SIPP and investment platform from the same providerNoAccepts US-resident members into the SIPP. The General Investment Account cannot be used standalone by a US resident, but can be used inside the SIPP
Morningstar Wealth InternationalIntegrated. UK SIPP administered on the Morningstar Wealth International platformNoAdviser-led by design. Broad investment access and a fee schedule that is straightforward to model
iPensions GroupNon-integrated. US residents are limited to the adviser-led US product. The Platform SIPP is not availableYesThe SIPP is only half the structure. A platform or other investment vehicle has to be appointed alongside it
IFGLNon-integrated. Pension trustee and administration onlyYesInvestments sit on a separately appointed platform. Check the wrapper-level cash retention

Table: provider acceptance policies, terms and fees change, sometimes at short notice, so treat any list of this kind as a starting point rather than a settled answer. Confirm the current position directly with the provider before applying.

What Each Provider Costs

Headline platform percentages are the number everyone compares, and they are also the number that tells you least. What actually determines your total cost of ownership is the number of charging layers, and the non-integrated structures have more of them by design.

The table below sets out the published scheme and platform charges for each provider. It deliberately excludes fund charges and adviser fees, because those are the same question for every provider on the list and would obscure the structural differences.

Cost elementNovia GlobalMorningstariPensionsIFGL
Set-up or establishmentNo establishment charge195 pounds one-off300 pounds350 pounds
Annual scheme or trustee fee60 pounds per quarter paid in advance, so 240 pounds a year, VAT included in the charge195 pounds a year, charged in advance600 pounds to 999,999 pounds of value. 1,100 pounds to 1,499,999. 1,600 pounds to 1,999,999. Above 2 million by agreement500 pounds for cash and the Ardan platform only. 600 pounds for wider investment access. Plus 0.1 percent on value above 300,000 pounds, capped at 1,500 pounds
Investment platform chargeTiered annual service charge, set in US dollars: 0.30 percent up to 500,000 dollars, 0.25 percent to 1 million, 0.15 percent to 2 million, 0.10 percent above. Not applied to cash. Plus 0.04 percent custody on non-cash assetsTiered: 0.35 percent to 250,000 pounds, 0.28 percent to 500,000, 0.21 percent to 1 million, 0.14 percent to 2 million, 0.07 percent to 5 million, 0.03 percent aboveNot included. One appointed platform is covered by the trust fee. 50 pounds a year for each additional provider, 150 pounds to change provider. The Platform SIPP with built-in investment access is not available to US residentsNot included. Charged separately by the appointed platform
Dealing charge5 dollars per fund trade for UK, Luxembourg and Irish domiciled funds, 10 dollars Channel Islands. 2 dollars per exchange traded fund plus 12.50 dollars custodian settlement. UK equities 0.05 percent per order, minimum 5 poundsMaximum 4 pounds per trade on funds, equities, bonds and exchange traded fundsNo charge through the member portal. 20 pounds for paper or electronic instructionsCharged by the appointed platform
Drawdown and income150 pounds a year for income drawdown. 200 pounds per crystallization event125 pounds a year for drawdown, 100 pounds per crystallization, combined cap 250 pounds plus VAT100 pounds a year for drawdown. 250 pounds for a pension commencement lump sum or an uncrystallized funds lump sum. 250 pounds per ad hoc payment150 pounds a year for regular income. 150 pounds per ad hoc payment. 225 pounds for a pension commencement lump sum
Exit or transfer outNone listed in the published scheduleNo exit or re-registration charge550 pounds for a UK resident, 650 pounds for an overseas resident, 1,250 pounds to an overseas schemeCharged per the schedule
Minimum transfer valueNone publishedNone published40,000 pounds75,000 pounds
Mandatory cash retentionNone at wrapper level, but interest is not paid on client cash and the margin is retainedNone at wrapper levelUp to approximately 3,000 pounds retained in the scheme bank accountMinimum 1.5 percent of plan value, floor 2,000 pounds, ceiling 8,000 pounds
US-specific servicingThe SIPP accepts US persons. The General Investment Account cannot be used standalone by a US resident, but can be used inside the SIPPA dedicated service tier for US taxpayers: SEC-regulated managers only, reporting aligned to IRS requirements, 195 pounds a year US tax report fee, and separate tiered platform chargesA dedicated product for US residents with its own fee scheduleNo US-specific service tier published

Table: figures are taken from the published schedule of each provider as at 30 July 2026 and are exclusive of VAT where applicable. Several providers index their fees annually and all reserve the right to change them on notice. Fund charges, dealing spreads, currency conversion and adviser fees sit on top of everything shown here. Verify the current schedule before you commit.

The layer most comparisons leave out

Two providers on this list require a minimum cash balance to be held inside the wrapper so that fees can be deducted. IFGL requires a minimum of 1.5 percent of plan value, subject to a floor of 2,000 pounds and a ceiling of 8,000 pounds, which means a 150,000 pound transfer arrives with a meaningful slice sitting in cash from day one. iPensions retains a cash balance in the scheme bank account for the same purpose.

This is not hidden and it is not improper. It is, however, a real and permanent drag on returns that does not appear in any headline percentage, and it is most damaging to clients in accumulation who are neither contributing nor drawing income. The integrated providers on this list do not operate an equivalent retention at wrapper level.

A worked example on a 250,000 pound pension

Taking the published figures above and ignoring fund and adviser charges, which apply either way:

  • Novia Global: 240 pounds of scheme administration plus the 0.30 percent annual service charge and 0.04 percent custody, giving around 1,090 pounds a year, or approximately 0.44 percent. Note that the service charge tiers are set in US dollars, so a pension of this size sits inside the first tier and the rate steps down as the dollar value crosses 500,000 dollars.
  • Morningstar Wealth International: 195 pounds of scheme administration plus 0.35 percent platform, giving around 1,070 pounds a year, or approximately 0.43 percent. Add 195 pounds if you are on the US taxpayer service tier, taking it to roughly 0.51 percent.
  • iPensions Group: the 600 pound annual trust fee, plus whatever the separately appointed investment platform charges. The second layer has to be quoted before the total means anything.
  • IFGL: the 600 pound core annual fee, plus the separately appointed platform, plus the effect of the cash retention. Our own review of the IFGL SIPP put the realistic all-in figure on a pension of this size at 1.5 to 2.0 percent a year once every layer was counted.

The point of the exercise is not that the integrated options always win. It is that with a non-integrated structure you cannot answer the question at all until the second contract is on the table, and a surprising number of clients sign the first one without ever having seen the second.

Hold a UK pension and live in the US?

Book a free consultation and we will review your options before you commit to a provider. Our advisers hold individual SEC authorization, which is the permission that matters when you live in the United States.

Self-Investing Is Not a Compliant Route for a US Resident

This is the part most people get wrong, and it is understandable. The wrapper is called a self-invested personal pension. The word self-invested describes how flexible the investment permissions are compared with an old insured personal pension. It does not mean you may run the arrangement yourself from a US address. We have written about this provider by provider, including in our article on whether you can self-invest a Novia Global SIPP. There are three separate barriers, and each one is enough on its own.

The dealing barrier

A UK platform that accepts investment instructions directly from a retail client living in the United States is dealing with that client inside the US regulatory perimeter. Doing so requires the firm to be registered in the US or to fit within a narrow exemption, and retail execution-only business does not fit. The consequence is simple: the providers on this list do not offer execution-only access to US-resident members, and their terms require an appointed, appropriately authorized adviser. The exposure attaches to the firm rather than to you, which is precisely why the firm will not let you do it.

There is a revealing detail in the Novia Global charging structure. Where an adviser is no longer registered on an account, the annual service charge increases. The structure assumes an adviser is in place and prices accordingly when one is not. That is what the market looks like when a proposition is built for advised clients from the ground up.

iPensions makes the same point from the other direction. It offers a self-invest option and a platform SIPP with investment access built in, and makes neither available to US residents. The only route open to you is the advised one. When two independent providers arrive at the same restriction, it is not a commercial preference.

The investment universe barrier

Most of the funds available on a UK platform are UK and offshore collectives that are not registered for offer to US persons. They are not marketed to you, and in most cases they cannot lawfully be sold to you. Left to your own devices, the investable universe collapses to a fraction of what the platform appears to offer, and the fraction that remains is rarely the one a sensible portfolio would be built from.

The advice barrier

Anyone recommending securities to a person resident in the United States needs the relevant US authorization. A UK adviser holding UK permissions alone cannot advise you, no matter how well they know UK pensions. This point is frequently glossed over by firms that describe themselves as regulated and leave the reader to assume the regulation covers their situation. It is worth asking directly, and you can check a firm or an individual on the public adviser database maintained by the SEC.

What happens if you try anyway

The usual route people attempt is to keep a UK address on file, or not to update the provider after moving. When it comes to light, and it generally does through routine residency checks or tax reporting, the consequences run from restricted dealing to the account being closed and positions liquidated on the timetable of the provider rather than yours. Forced sales inside a pension are not a UK tax event, but they remove your control over timing entirely, and they can crystallize a portfolio at exactly the wrong moment.

One point worth clearing up: PFIC

US-connected clients are often told that PFIC rules make UK funds unusable. Inside a UK SIPP that is not the case. A reporting exception applies to interests held through an arrangement treated as a foreign pension fund under an income tax treaty, set out in the regulations under section 1298(f) and readable in the Code of Federal Regulations. The PFIC problem arises on investments held outside the pension, such as a general investment account or an ISA. It is a real issue, but it belongs to a different part of your balance sheet.

What Actually Makes the Structure Work

The right arrangement for a US resident has two halves that have to fit together.

  • A UK-registered SIPP from a provider that formally accepts US-resident members, so the pension itself remains a UK pension with UK tax treatment intact.
  • Investment advice delivered by an adviser holding the relevant US authorization, so the portfolio inside the wrapper can be built and managed lawfully.

Cameron James USA advisers hold individual SEC authorization. Cameron James is not itself SEC registered as a firm. That authorization is what allows a portfolio to be constructed for you, rather than leaving you with a shortlist of whatever remains once the restrictions have been applied. Our International SIPP page covers how the wrapper works in more detail, and our UK pension and SIPP transfer page for US residents sets out the transfer process end to end.

What This Costs

We use a hybrid fixed fee for UK pension transfer advice rather than an open-ended percentage of your fund. The structure is a fixed base fee plus a percentage of the transfer value, with the base fee higher for a defined benefit or final salary transfer than for a defined contribution transfer, and an additional fixed amount where more than one pension is being transferred. Our current fees are published in full, and you should take the figures from there rather than from an article, because a fee page is maintained and an article ages.

The reason the structure matters more than the headline is that because a substantial part of the fee is fixed, the effective percentage falls as the pension value rises. Advising on a larger transfer is more work than advising on a smaller one, but it is not proportionally more work, and the fee should reflect that. A pure percentage fee charges you five times as much for a transfer that takes perhaps twice the time.

For context on what the market permits rather than what we charge, the Novia Global charging schedule allows an adviser initial charge of up to 5 percent of the transfer value to be facilitated through the platform. On an 800,000 pound transfer that ceiling is 40,000 pounds. We are not suggesting anyone routinely charges it, but it is worth knowing what the headroom is when you are comparing quotes, because a percentage that sounds modest against a large pension can be a very large number in absolute terms.

Separately, we do not charge an initial advice fee on US-connected investment accounts or on US pensions. That is a different thing from UK pension transfer advice, which is chargeable as described above, and the distinction is worth stating plainly so the two are not confused. Ongoing advice fees and the underlying platform and fund charges still apply in both cases, and we will set all of them out in writing before you decide anything.

How to Choose Between Them

There is no single best provider, and any article that names one without knowing your circumstances is selling something. The variables that actually move the answer are your pension value, whether the transfer is defined contribution or defined benefit, the currency you intend to draw income in, how long you expect to remain in the United States, and whether you want the simplicity of one counterparty or the flexibility of two.

As a general observation, the integrated options tend to win on simplicity and on total cost at small and mid-size pension values, because you are paying one provider rather than two. The non-integrated options earn their place where there is a specific reason to want a particular platform or investment vehicle inside the wrapper. What should not be a variable is whether the arrangement can be operated lawfully. That part is not a preference.

A Note From Jonathan Laws

Jonathan Laws, ACA Ch.FCSI, Senior Independent Financial Adviser, Cameron James

Jonathan Laws, ACA Ch.FCSI, Senior Independent Financial Adviser, Cameron James

“The question I am asked most often about this list is which provider is cheapest, and it is almost always the wrong question. Two of the four cannot be priced at all until you know what platform is going inside them, and the answer for the other two changes with pension size and with the dollar exchange rate. What separates a good outcome from a poor one is rarely a few basis points on a platform fee. It is whether every layer was visible before anything was signed.
The other thing I would say to any expat reading this is not to spend energy looking for a self-invest route. It does not exist for a US resident, and the reason is that the provider would be the one taking the regulatory risk, not you. I understand the instinct, particularly for someone who ran their own portfolio perfectly well before they moved. But the practical choice is between a properly advised UK pension and a pension that quietly stops working, and the second option tends to reveal itself at the worst possible time.”

Frequently Asked Questions

Which SIPP providers accept US residents in 2026?

Novia Global and Morningstar Wealth International are the two integrated options most commonly used, with the SIPP and investment platform from the same provider. iPensions Group and IFGL accept US-resident members on their adviser propositions but do not include an investment platform, so a separate vehicle has to be appointed. Provider policies change, so confirm the current position before applying.

Can I open a SIPP as a US resident without an adviser?

No. The providers that accept US-resident members require an appointed adviser with the relevant US authorization, and they do not offer execution-only access. That is a regulatory constraint on the provider rather than a sales condition.

Is an FCA-authorized UK adviser enough if I live in the United States?

No. UK permissions do not authorize anyone to advise a person resident in the United States on securities. The operative permission is the US one. Ask any adviser directly whether they hold SEC authorization, and check the answer on the public adviser database.

Do PFIC rules apply to the funds inside my SIPP?

Holdings inside a UK SIPP fall within a reporting exception during accumulation, under the rules covering interests held through a treaty-recognized foreign pension fund. PFIC becomes relevant for investments held outside a pension wrapper, such as a general investment account or an ISA. Confirm your own position with a cross-border tax adviser.

What is the difference between an integrated and a non-integrated SIPP?

An integrated SIPP comes with the investment platform built in, so there is one provider, one set of terms and one fee schedule. A non-integrated SIPP is the pension wrapper only, and an investment platform or other vehicle has to be appointed inside it, which means two counterparties and two fee schedules.

My UK provider has told me to move because I live in the US. How long does a transfer take?

Four to twelve weeks is typical, depending on the complexity of the holdings and whether an in-specie transfer is possible. Starting late increases the risk that your existing provider liquidates on its own timetable. Do not withdraw cash from the pension as a way of solving the problem, because premature withdrawals trigger UK tax charges and permanently remove the money from the wrapper.

I am a UK expat in the US rather than a US citizen. Does this list still apply?

Yes. What drives provider acceptance and the advice permission is US tax residence rather than nationality. A UK national who is US tax resident faces the same restrictions as a US citizen living there. Your UK position may differ on other points, particularly inheritance tax and long-term residence, so both sides need looking at together.

Why is there a safeguarding appointment when I transfer?

UK transfer regulations require ceding schemes to carry out due diligence before releasing a transfer, and one of the flags is triggered where the receiving scheme includes overseas investments, which routes many International SIPP transfers through a guidance appointment with MoneyHelper. It is provided at no cost and we support you through it.

Get a clear answer on your own position

One conversation establishes which structures are open to you and what a transfer would cost. If transferring is not the right move, we will tell you that.

Related Articles

These are existing Cameron James USA articles covering the questions that come up alongside choosing a provider.

UK Pension and SIPP Transfer for US Residents
The transfer pillar. Options, US taxation of UK pension income, adviser regulation, costs and the full process.

International SIPP
How the wrapper works, and how it differs from a standard UK SIPP for a member living abroad.

The IFGL SIPP Review 2026
Our full review of the non-integrated option, including the cash retention and the all-in cost once every layer is counted.

iPensions and the Momentum International SIPP Review
Our full review of the iPensions range, including the difference between the adviser and platform propositions.

Novia Global SIPP: Can You Self-Invest?
The self-invest question answered for one provider in detail, and what the adviser-led design means for expats in the US.

Interactive Investor SIPP Closing for US Residents
What an enforced transfer deadline looks like in practice when a platform exits the US-resident market.

Disclaimer: Some of the content of this communication was provided by third parties of Cameron James. 
We have not verified the information contained herein, but we believe the content is reliable. None of this content should be construed as legal, accounting or tax advice.  Many legal issues, accounting or tax regulations are complex and often have highly-individualized requirements, you should seek the advice of a competent professional if you have specific questions.


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