Aviva Life & Pensions UK Limited · DRN-6155903

The complaint Mr B complains that Aviva Life & Pensions UK Limited (Aviva) hasn’t evidenced that his pension is invested in the correct funds. He is also concerned that some of his funds may not exist as described. He feels that Aviva should enable online access to unit prices and should update his scheme rules. What happened Mr B has an Executive Pension Plan (EPP) with Aviva. I understand that this plan was previously held by another provider. And that Mr B could access daily unit prices online with that provider. Mr B became concerned about his investments in October 2024. He realised he couldn’t find unit prices for the funds in his pension on Aviva’s website. He also felt that the fund names provided by Aviva didn’t match those he recognised from his former provider. He says he wasn’t informed that his previous funds had been renamed or mapped into Aviva’s AP Series 4 funds, and when he compared Aviva’s internal unit prices with figures on external sites, the prices didn’t match. On 30 December 2024, Mr B complained to Aviva. He felt that it had incorrectly classified his investments. And that it had failed to provide him with International Securities Identification Number (ISIN) codes or Stock Exchange Daily Official List (SEDOL) codes for his investments. He was also unhappy as he expected more up-to-date scheme rules to have been provided. On 7 January 2025, I understand that Aviva emailed the plan details to Mr B. It also explained that the price series of the funds was dependent on the product a consumer was invested in. It said that Mr B’s plan was a Multi Executive Plan Mark 1. And that under that plan, the price series of invested funds was 4. It also provided the details of the funds invested with ISIN codes where available. Mr B didn’t think it was correct that his funds were invested in the series 4 funds. He felt the prices Aviva quoted corresponded to series 1 funds. On 21 January 2025, Aviva said that Mr B called it to ask for the fund names, bid price and current value. It said it provided all the details over the phone. Aviva issued its final response to the complaint on 5 February 2025. It acknowledged it’d incorrectly classified Mr B’s investments as “serial funds” instead of “series funds”. It said the error had occurred because of an internal system issue, which it’d corrected. It apologised for the confusion and inconvenience this may have caused. Aviva also acknowledged that it hadn’t provided Mr B with the full ISIN codes and fund names as quickly as it should. But it said it had now provided this information. Aviva offered Mr B £75 for the inconvenience the poor service had caused. Mr B was unhappy with this response. He referred his complaint to this service on 18 July 2025. He said he disagreed with the following points:

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• Aviva maintained that his pension was invested in its series 4 pension funds. He felt that other evidence showed that some of his funds were invested in its series 1 pension funds. And some of his funds appeared to have unit prices that were in a fixed proportion to the unit prices of the equivalent series 1 pension funds. He felt that Aviva had failed to address this fundamental issue. • Mr B wanted Aviva to be transparent about what had happened to the funds he’d held in his pension before the transfer to Aviva. He also wanted to know why it couldn’t identify two of his funds by internationally recognisable identification codes. • Mr B wanted Aviva to explain why it couldn’t provide unit prices for his funds on its fund centre website. He said he’d had access to such information before the transfer to Aviva. • He also wanted it to explain why it hadn’t updated the scheme rules for his pension to keep them current. Aviva provided information about Mr B’s pension plan. This included the five fund factsheets for the funds he was invested in. It said that the factsheets were for the fund series for which it had the highest investment. Therefore they didn’t necessarily represent the fund series which Mr B was invested in. However, the background investment was the same. Aviva also provided the plan’s terms and conditions. And confirmed that while Mr B didn’t have access to view fund prices for his plan on its website, he could call, email or write to it to request this information. On 30 October 2025, Aviva sent Mr B information about his plan that he said he didn’t request. It sent him current values for each of his five funds, which it said were as follows: Av Overseas AP Series 4 Av Higher Inc AP Series 4 Av Nth America AP Series 4 Av Europe exUK AP Series 4 Av Globl Mangd AP Series 4 Aviva said that it calculated the current value by multiplying the number of units in each fund by the bid price on the valuation date. Aviva also noted that while it had intended to provide online availability on all its existing products for its customers, it had become apparent that there would be a number of customers for whom this would not be possible. It acknowledged this would disappoint Mr B and apologised. It provided an email address to which Mr B could send any requests. Mr B told this service that his main concern was that Aviva wasn’t being truthful and was withholding information from him. Our investigator didn’t think that Aviva needed to take any further steps to put things right. She felt the evidence showed that Aviva had acted fairly. She felt it’d provided accurate information about Mr B’s fund holdings and unit prices. And that the differences Mr B had identified with external investment data had arisen from normal publication delays, not from Aviva pricing his funds incorrectly.

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Our investigator said she’d checked Aviva’s calculations from its 30 October 2025 letter. She said the valuations reconciled exactly with the unit prices provided. And that the charges listed were consistent with the product features. She felt this supported her view that Aviva had accurately recorded the funds and unit pricing on Mr B’s pension. Our investigator acknowledged Mr B had expected continued online access to daily unit prices for his specific product after his pension had been transferred to Aviva. She said Aviva had confirmed that his product wouldn’t have online access. But felt that it’d clearly signposted other ways to obtain the information he wanted. She therefore didn’t think Aviva had done anything wrong on this point. Mr B felt that our investigator had misunderstood what his complaint was about. He said this was that Aviva had told him that his pension was invested in funds with designations that didn’t correspond with those of the funds with the ISIN or SEDOL codes it’d provided to him. He also said that for two of his funds, Aviva hadn’t been able to provide the ISIN codes. He felt this meant that those funds weren’t real globally recognisable securities that could be traded. Instead he felt they were internal hypothetical Aviva funds whose prices couldn’t be verified. Mr B said that if he’d been made aware that the price of some of his funds depended on prices that Aviva simply assigned to them, without the fund being invested in actual securities that supported the pricing of the fund. He wouldn’t have chosen to invest in them. Mr B said that his complaint was also that the unit prices that Aviva had provided to him for specific dates didn’t match those of the series 4 funds it said he was invested in. But that they did match those of its series 1 funds that had the ISIN codes it’d provided. Mr B felt that there was no evidence to support that Aviva had accurately recorded the funds on his plan, or that his funds were series 4 funds. He said this was because the prices given by Aviva didn’t match those of series 4 funds of the same name on a trusted external site for the same date. Mr B still felt the unit prices for his funds should be available online. He also felt that Aviva had failed to provide him with a reasonable alternative for obtaining the daily fund prices he wanted. He said that calling Aviva involved excessive waiting time and was very inconvenient. Mr B said his complaint wasn’t that Aviva was pricing his funds incorrectly, but that it couldn’t correctly identify the funds he was invested in so that he could independently verify that it was pricing them properly. He also felt Aviva wasn’t being honest and transparent about which funds his pension was invested in, and how those funds were priced. I told Aviva that I felt Mr B had provided detailed arguments and calculations for why he believed his funds were either series 1 pension funds or linked to the prices of series 1 funds. While I acknowledged it’d consistently maintained that his funds were series 4 pension funds, I felt it would be helpful if Aviva explained to Mr B why he had been able to replicate the price of what it said was series 4 funds by using published data on series 1 funds. Following my request, Aviva wrote to Mr B on 13 April 2026. It said its fund managers had confirmed that the series numbers varied based on the different systems or platforms within the company. And that although for Mr B’s product the fund was labelled as series 4 on its administration platform, the fund could’ve been set up on other platforms as a different series. It said that if Mr B had any further questions, he should contact it. As agreement couldn’t be reached, the complaint has come to me for a review.

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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. Having done so, I’m not going to uphold it. I know my decision will be disappointing to Mr B. I’ll explain my reasons for it. I can see that Mr B has provided a detailed response to much of what our investigator said in her view. Before I start, I’d like to explain that my decision below will focus on the crux of his complaint. This means that while I’ve read all the information provided by both parties, I won’t be commenting directly on every single point made. But I have considered each point in making my overall decision. I consider that the crux of Mr B’s complaint is that he doesn’t believe Aviva accurately recorded which pension series his pension is invested in and how those funds are priced. Mr B also feels that Aviva hasn’t been honest and has withheld information from him. So I’ve considered whether the evidence shows Aviva made a mistake with the pension series. Before I’ve done this, I want to explain what a pension or fund series means. A pension series refers to a specific, categorised range of investment funds within a pension product. Providers use these series to differentiate between investment options, which can affect the associated fees, charges, and performance of the fund. A pension provider will often release new series of its pension funds. In most cases, they are all invested in the same underlying fund and share the same fund manager and investment strategy. Did Aviva make a mistake with the pension series classification? I can see that Mr B has carried out detailed calculations using third party information. And that as he felt those calculations didn’t tally with what Aviva had told him, he felt it must have made a mistake. While I can see that Mr B feels very strongly that Aviva hasn’t been honest with him, I’ve not found any evidence that it has provided Mr B with incorrect information about his pension series. Nor have I found any evidence that Aviva has tried to withhold information from Mr B. The evidence shows that Aviva has explained to Mr B that the price series of the funds depends on the product a consumer is invested in. And that for Mr B’s product, the price series was 4. Mr B felt this wasn’t correct. He felt the prices Aviva had quoted corresponded to series 1. Aviva has also written to Mr B on 13 April 2026 to tell him that the fund could’ve been set up on other platforms as a different series. I’m satisfied that this explains why Mr B has been able to carry out calculations for some of his funds based on publicly available third-party information about series 1 funds. Overall, I’ve not seen any evidence that Aviva has made a mistake with the pension series classification. In its final response letter, Aviva said it’d incorrectly classified Mr B’s investments as “serial funds”, rather than “series funds” in its internal systems. It also acknowledged that it hadn’t provided Mr B with the full ISIN codes and fund names for his investments as quickly as it should have. I consider that the £75 Aviva offered Mr B for the inconvenience the poor service this caused was fair.

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Mr B also feels that if Aviva had made him aware that the price of some of his funds depended on prices it simply assigned to them, rather than the fund being invested in actual securities that supported its pricing, he wouldn’t have chosen to invest in them. I do understand that Mr B is unhappy that some of the funds he’s invested in don’t have publicly available unit prices. And that he considers this is because the funds aren’t “proper” funds backed by actual securities that support the pricing of the fund. However, I’m satisfied that Aviva has provided Mr B with all the relevant fund factsheets, so he should now know what his funds are invested in. I can also see that Aviva has sent Mr B charge information. So he knows what each fund is costing him. I’m also happy to see that Aviva has made it clear that if he has any further questions, he can contact it. I’m therefore satisfied that Mr B is in a fully informed position about the funds he’s invested in. As such, he can choose to change funds if he’s not happy with his current investments. I went on to consider Mr B’s complaint that the unit prices for his funds should still be available online. And that Aviva had failed to provide him with a reasonable alternative for obtaining the daily fund prices he wanted. Should Aviva provide fund prices online? I acknowledge that Mr B is very unhappy that he can no longer access unit prices through his pension provider’s website. I can see that he expected to still have such access after his pension was transferred to Aviva. And that Aviva itself supported this expectation when – in 2018 – it told him it expected to provide such access by the end of that year. It appears that it wasn’t until March 2025 that Aviva told Mr B he wouldn’t get that access. While I appreciate how disappointing this is, I can’t reasonably require Aviva to provide the online access Mr B wants. The role of this service isn’t to comment on the processes operated by a business, that’s the role of the regulator, the Financial Conduct Authority. Instead, our role is to look at how business’ rules and processes are applied to individual consumers’ circumstances and, where they have created unfairness, how that unfairness can be resolved. We don’t have the power to tell a business to change the way it operates. In addition, I can see that Mr B said that his previous provider told him: “there will be no change to your policy terms and conditions and any benefits will not change as a result of these transfers. There will be no changes to the way we service your policy and you can still contact us on the same telephone numbers and at the same address as before.” But this doesn’t specifically state that online access to unit prices would continue after the transfer. And I haven’t been able to find any contractual commitment to such access in the policy’s documentation. As such, I can’t fairly say that Aviva has failed to follow the policy’s terms and conditions in not providing access to unit prices online. I do appreciate that online access to unit prices would be beneficial to Mr B. And while I understand that calling Aviva may be inconvenient, I can’t reasonably say that Aviva has done anything wrong by only providing Mr B with access to the information he wants by calling it, emailing it or writing to it. I’ve not found any evidence that Aviva needs to take any further steps to put things right. Therefore I don’t uphold the complaint. My final decision For the reasons I’ve given above, I don’t uphold the complaint.

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Under the rules of the Financial Ombudsman Service, I’m required to ask Mr B to accept or reject my decision before 13 May 2026. Jo Occleshaw Ombudsman

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