The CII AF7 September 2025 Exam in Review
We’re looking at the exam guide from the CII’s September 2025 sitting of AF7 – the Pension Transfers exam.
This article is correct as at 16 December 2025.
You can find the exam guide here.*
In this paper, Section A had 28 marks allocated to it, and Section B had 72 marks. Interestingly, the weighting allocated to Section A was significantly lower than the usual average of around 31-34 marks, following a previous sitting in which it was significantly higher at 36.
Section A
As is usually the case, the opening question was a regulatory one and concerned the rules regarding contingent charging and eligibility for the serious ill-health carve-out from the general ban. The question asked the relevant knowledge and experience the FCA expected the firm to have when dealing with the client. This was one rather out of left field and feedback was that it was not particularly well answered with a lot of candidates answering the question they wish was asked rather than the one which was actually asked. For example, many candidates listed the qualifying conditions for the exemption or means of dealing with a vulnerable client, which does highlight the importance of reading the question carefully.
In Question 2, we were asked six situations where a scheme member does not have the statutory right to transfer. There were eight possible answers here with some of them being relatively straightforward examples such as members within 12 months of the normal retirement date, those who have already taken benefits, unfunded public sector schemes or those taken into the Pension Protection Fund (PPF). However, other possible answers were a bit more imaginative such as cases where a red flag had been raised for potential scams and ones where the member had not met the statutory advice requirement. Most candidates scored well on this question according to the feedback.
Next up, we met Aleksander whose scheme was about to enter the PPF. The question asked candidates to explain how his benefits would be impacted as a result. The PPF is tested regularly in the CII pension exams and well-prepared candidates could, and did, score highly on this question with many gaining the full six marks available.
Finally, in this section we were introduced to Samir who had recently transferred his pension and was about to take an income using flexi-access drawdown. The question asked the factors to take into account when determining a safe withdrawal rate. This, again, is something which has regularly been covered in AF7 over the years, and most candidates were able to score good, if not quite maximum, marks.
Here's a review of the Sep 25 exam paper for #CII #AF7. Share on X
Section B
Case Study 1
In this case study, we met Donna and Craig, 57 and 54 with two teenage children, both of whom were semi-retired. Donna and Craig were an interesting contrast with her earning £46,000 and having significant investment experience and an adventurous attitude to risk and him earning £8,000 part-time and having limited experience and a cautious attitude. They were unsure of their income requirements in retirement, had no capital needs but wanted to ensure their children were protected in the event of either of their deaths.
The first question concerned the additional information which would be required from the scheme administrator in order to make a recommendation as to whether Craig should accept the £427,500 transfer value. Fact-finding questions are a staple diet of AF7, and the question was well answered according to the feedback, with a high proportion of candidates gaining the maximum ten marks.
Next was a reverse advice question where we were given the recommendation that Craig should not transfer his pension and asked the reasons for it. There was plenty which immediately sprung to mind here including uncertain income retirements, cautious attitude to risk, inexperience with investments, good health, other flexible assets and no other secured pension besides the state one. Again, many candidates were able to score high, or even the maximum twelve, marks.
Finally, we had a trickier one which asked candidates to consider the factors that they should consider when preparing a recommendation on how best to draw on their existing DC funds to top up their income until they retire. This was for 15 marks and it was potentially a bit difficult to be sure exactly what type of answers the CII was looking for with the question. However, feedback did comment that answers were variable with failure to relate them to the information in the case study being the most common failing.
Case Study 2
This case study surrounded Barry and Julia, aged 63 and 61, married and in excellent health. Julia had two sons and three grandchildren from a previous relationship. Both have preserved defined benefit pensions with previous employers. Their needs were £2,500 inflation proofed income for their cost of living expenditure and £1,000 to cover discretionary spending and Julia was keen to leave a legacy to her family.
First up, we again had a recommendation question with the recommendation given that Barry takes his full scheme pension with no PCLS and that Julia transfer her pension to a personal scheme. We were asked to justify these recommendations. Again, there was plenty of information in the case study for well-prepared candidates to get their teeth into and the question was well answered by many, though few achieved the full 14 marks.
Following on from this was a question surrounding temporary annuities and the factors which advisers should take into account when deciding whether to meet an income shortfall using this or flexi-access drawdown. This was a slightly unusual one for AF7, with temporary annuities more commonly covered in J05. Answer standard was mixed, with the CII commenting that some candidates confused temporary annuities with full ones, whilst others made technical errors like stating that temporary annuities did not trigger the money purchase annual allowance.
Finally, we had a question on the use of a spousal bypass trust for Julia’s death benefits. Whilst these are rarer following the changes introduced by the pension freedoms, they still have a place in circumstances such as those in the case study where the parties to the marriage have families from previous relationships. They are also occasionally tested in AF7 and other pension papers. This was for quite a meaty 12 marks and asked us to outline the factors to take into account when deciding whether Julia leave her residual pension fund to Barry or to a spousal bypass trust. The answers covered a range of factors and it would have been difficult to achieve close to full marks. The CII commented that scores were mixed and well-prepared candidates performed well, however, there were technical misunderstandings such as candidates thinking that the trust took effect immediately rather than only on death.
Whilst there were a number of ‘staple diet’ questions and the usual questions regarding fact-finding and justification of advice, this paper was slightly more technical than is often the case in AF7. There was enough low-hanging fruit there for those who were better prepared to pass, but there were also a number of less frequently tested areas of the syllabus thrown in.
As AF7 is a specialist paper we thought it might be useful to see what has been tested over the previous papers starting with the sitting in September 2022.
| September 2022 | APTA Guaranteed annuity rates Risks of transfer Transfers and IHT 34 marks | Ill health early retirement Lifetime allowance Death benefits Reasons not to transfer The PPF 31 marks | Additional information from the scheme Capacity for loss Reasons for transfer 35 marks |
| March 2023 | Contingent charging CETV calculation Employer covenant Sequencing 34 marks | Death benefits Reasons to transfer Cashflow modelling Investment strategy 33 marks | Information regarding the scheme Factors to consider Spousal bypass trusts 33 marks |
| September 2023 | Personalised charges communication GMP benefits Statement of entitlement Factors that impact transfer values 31 marks | Fact finding (client) Recommendation not to transfer Cashflow/stress testing. 32 marks | Which pension to transfer Annuity purchase Death benefits Class 3 national insurance 37 marks |
| March 2024 | Triage services Capacity for loss considerations Pension protection fund Guaranteed annuity rates 31 marks | Additional information from scheme administrator Appropriate pension transfer analysis Reasons for retain recommendation Ways to meet income shortfall 36 marks | Reasons to transfer one scheme over the other Flexi-access drawdown vs short-term annuity Spousal bypass trusts Class 3 NICs 33 marks |
| September 2024 | Abridged advice Employer covenant Attitude to transfer risk Statutory timescales 32 marks | Additional information from the client Other ways to meet objectives Death benefits and tax treatment 29 marks | Vulnerable clients Investment strategy fact finding Reasons to make a recommendation Sequencing risk Expression of wish forms 39 marks |
| March 2025 | Drivers of vulnerability Appropriate pension transfer analysis Guaranteed minimum pension TTFAC application process 36 marks | Fact-finding from the scheme Personal pension death benefits Factors to consider in making a recommendation 29 marks | Reasons for recommendation Cashflow modelling Investment strategies 35 marks |
We offer resources to support you as you revise for the AF7 Pension Transfers exam. AF7 has a large number of ‘staple questions’ which come up time and again in the exam paper.
Our ‘Core Knowledge’ resource focuses on these ‘staple questions’ and includes questions, answers, detailed explanations, and cross-references to the CII study text. The resource also includes some of the core calculation questions you would be expected to understand. This is a resource that we developed specifically for the AF7 exam.
Grab the resources you need!
If you’re studying for your CII AF7 exam, and you’re wanting to feel confident on exam day, grab our free taster to try out one of Brand Financial Training’s resources for yourself. Click the link to download the AF7 Core Knowledge Taster now!
* The CII has updated their retention policy and now only provides the last two exam papers. Older papers referenced in this article may no longer be available on the CII website.
