Working Document — April 2026
Note: Certain product details (minimum investment, lock-up/notice period) are referenced from the draft term sheet prepared by Dillon Eustace. However, we understand the actual notice period for the notes may be 30 days rather than the 12-month lock-up referenced in the draft documentation. This distinction is significant and needs to be confirmed with AFX, as it materially affects how SIPP providers will assess the product.
AFX Fixed Income DAC is an Irish designated activity company issuing debt securities (notes) listed on the Vienna MTF, cleared through Euroclear and Clearstream, with an assigned LEI and ISIN. The notes pay 1.5% per annum and are backed by Class A Shares in afx Wealth Limited, a Cayman-domiciled fund running diversified algorithmic trading strategies across FX, indices, commodities and crypto CFDs.
The question is whether UK Self-Invested Personal Pension (SIPP) providers will accept these notes onto their approved investment panels, allowing pension holders to invest.
The short answer from Stephenson Harwood's initial guidance: there is nothing that would prohibit a SIPP trustee from investing in debt instruments issued by an Irish SPV and listed in Vienna. The more complex question is whether trustees should invest, given their obligations around beneficiary interests, diversification, and investment advice. In practice, finding a willing SIPP provider will require careful targeting and preparation.
Every FCA-regulated SIPP operator maintains a permitted investments list. Investments are classified as either standard or non-standard, and this classification drives the entire approval process.
| Standard Assets | Non-Standard Assets |
|---|---|
| Cash, listed equities on recognised exchanges, UK gilts, rated corporate bonds, OEICS, unit trusts, ETFs, investment trusts, commercial property | Unrated bonds, unlisted securities, overseas property, storage pods, UCIS, loan notes, anything not readily realisable within 30 days |
| Minimal due diligence, no capital surcharge, fast approval | Enhanced due diligence, capital adequacy surcharge, investment committee review |
Key point: Despite being listed on the Vienna MTF with an ISIN and clearing through Euroclear, the AFX notes will almost certainly be classified as a non-standard asset by UK SIPP providers. The Vienna MTF is a multilateral trading facility, not a "recognised stock exchange" under FCA/HMRC definitions. The notes are unrated, the issuer is unregulated, and there is a lock-up/notice period that may affect realisability. This means enhanced due diligence applies.
Since September 2016, the FCA has required SIPP operators to hold additional regulatory capital against non-standard assets. Under the IPRU-INV rules, operators must hold capital equal to a percentage of the value of non-standard assets under administration. This directly affects providers' willingness to accept non-standard investments because every pound of non-standard assets on their books increases the capital they must hold.
This is the single biggest reason why many SIPP providers have stopped accepting non-standard assets altogether. James Hay, for example, closed its doors to all new non-standard investments. Several smaller operators (Rowanmoor, Gaudi, Hartley) have gone into administration partly due to the capital burden of legacy non-standard holdings.
The providers who still accept non-standard assets charge higher fees to offset the capital cost, and are highly selective about which investments they approve.
Based on the FCA's guidance (FG13/8), the FCA's 2023 Dear CEO letter to SIPP operators, and published due diligence processes from providers like Curtis Banks, Dentons, and Westerby, the following questions will be asked during any panel application. AFX should be prepared with clear answers for each.
Is the investment permitted by HMRC for tax-relieved pension schemes?
Yes. Listed debt securities are permissible pension investments. No taxable property issues arise.
Is the investment readily realisable? Can it be sold within 30 days?
This is a critical point. The draft term sheet prepared by Dillon Eustace references a 12-month lock-up period for the underlying Class A Shares. However, we understand the actual notice period for the notes may be 30 days. If confirmed, this is a significant positive: a 30-day notice period would meet the standard realisability threshold that most SIPP providers use to distinguish standard from non-standard assets. This single point could materially change how providers assess the product. Confirmation from AFX is needed.
What is the credit rating of the issuer/notes?
The notes are unrated. No credit rating has been obtained. This will be a concern for most providers.
Is the issuer regulated by a recognised authority?
The DAC itself is not regulated by the Central Bank of Ireland or any equivalent body. It is a special purpose vehicle. The underlying fund's investment manager (afx Financial Management Limited) operates from the BVI.
What is the underlying investment strategy?
Diversified algorithmic trading across FX, CFDs, indices, commodities, and crypto CFDs. The fund uses leverage. Providers will want to understand the risk profile and track record.
What protections exist for investors?
Notes are limited recourse obligations secured against the DAC's holding of Class A Shares in the fund. Investors could lose their entire investment. The orphan SPV structure (shares held on charitable trust by Waystone) provides issuer independence.
Is the investment introduced by an FCA-regulated adviser?
This is critical. Under FG13/8, SIPP operators must conduct due diligence on introducers. If the investment is recommended by an FCA-regulated adviser, providers are significantly more likely to accept it.
What are the fees, charges, and exit terms?
To be confirmed. Providers will want a full breakdown of all costs to the investor including any performance fees at the fund level.
The UK SIPP market is broadly split into platform SIPPs (Hargreaves Lansdown, AJ Bell, Fidelity) which only accept standard assets, and Full/Bespoke SIPPs which may consider non-standard investments. Only the latter category is relevant here. Many providers that previously accepted non-standard assets have either closed to new non-standard business or gone into administration.
The following providers still actively consider non-standard investments and would be the most productive initial conversations. This is not exhaustive and is based on publicly available information as of April 2026.
| Provider | Why They're Relevant | Contact |
|---|---|---|
| Mattioli Woods | Listed company, explicitly states they "continue to allow investments classically seen as non-standard". Risk-based approach. Dedicated IFA relationship managers. | [email protected] 0333 034 4110 |
| Curtis Banks (Nucleus) | Major bespoke SIPP operator. Published non-standard investment process. Requires FCA-regulated adviser involvement. Part of Nucleus Financial group. | nucleusfinancial.com /curtis-banks |
| Westerby Trustee Services | Long-established specialist. Accepts non-standard assets with FCA-regulated adviser involvement. Published guidance on their process. | sipp-ssas-pensions.co.uk |
| Dentons Pensions | Wide range of permitted investments. Published detailed investment guidance document. Considers non-standard on a case-by-case basis. | dentonspensions.co.uk |
| IPM Pensions | Bespoke SIPP operator. Investment flexibility is a selling point. Cautious but considers case-by-case. | ipm-pensions.co.uk |
| Yorsipp | Smaller operator. Full SIPP permits some non-standard investments subject to due diligence. Competitive fees. | yorsipp.com |
Providers to avoid: James Hay (stopped all new non-standard investments), Rowanmoor (administration), Gaudi (FSCS default), Hartley Pensions (FCA action), and all platform/retail SIPPs (standard assets only).
Stephenson Harwood's initial view was candid: while there is no legal prohibition on SIPP trustees investing in the notes, "it may be that in practice [AFX] struggles to find a SIPP trustee who will consider the proposed investment to be a compelling proposition." Their recommendation was to speak directly to UK SIPP providers before incurring the cost of formal legal advice.
| Hurdle | Severity | Can It Be Addressed? |
|---|---|---|
| Non-standard classification | Medium | Unavoidable given the product structure, but some providers do accept non-standard assets. Target those providers specifically. |
| Capital adequacy cost to provider | High | Providers will charge higher fees (typically £1,000+ setup plus annual charges). This cost is passed to the investor. Unavoidable under current FCA rules. |
| No credit rating | High | Obtaining even a basic rating would significantly improve acceptance. Without one, providers must rely entirely on their own due diligence of the issuer and fund. |
| Unregulated issuer | Medium | The DAC is an SPV, which is normal for structured note issuance. The orphan structure via Waystone is industry-standard. Providers familiar with structured products will understand this. |
| Algorithmic/leveraged strategy | High | FX algo trading with leverage will concern trustees who must act in beneficiaries' best interests. A strong, audited track record and clear risk management framework are essential. |
| Lock-up / realisability | Potentially Low | This could be the most important point in the entire briefing. The draft term sheet from Dillon Eustace references a 12-month lock-up for the underlying fund shares, but we understand the actual notice period for the notes may be 30 days. If confirmed as 30 days, this removes one of the biggest objections SIPP providers would have. A 30-day realisability window is the threshold most providers use when classifying investments. It would not automatically make the notes a standard asset (other factors still apply), but it would significantly reduce provider concerns about liquidity risk and could lower the severity of several other hurdles. This needs to be confirmed and clearly documented in any product summary sent to providers. |
| FCA-regulated introducer required | Medium | Most providers require the investment to be recommended by an FCA-regulated adviser. This is a distribution requirement, not a product defect. Addressable through the right adviser network. |
Stephenson Harwood recommended speaking directly to UK SIPP providers before paying for formal legal advice. That is the right approach. The following steps would give the clearest picture of what is achievable and what needs to change.
Prepare a one-page product summary
A clean summary of the notes: issuer, listing, ISIN, clearing, interest rate, lock-up terms, underlying strategy, auditor, legal counsel. This is what providers will want to see first before deciding whether to conduct full due diligence.
Confirm the notice period is 30 days, not 12 months
This is arguably the single most important point to clarify. The draft term sheet references a 12-month lock-up, but we understand the actual notice period is 30 days. If that is correct, it should be clearly stated in all product documentation because it materially changes how SIPP providers will view the product. A 30-day notice period meets the standard realisability threshold and removes one of the biggest potential objections.
Approach 2-3 providers for an informal conversation
Start with Mattioli Woods and Curtis Banks. Frame it as an exploratory discussion: "We have a listed, ISIN-bearing note cleared through Euroclear. Would this be something your investment committee would consider for your Full SIPP?" Their response will tell you exactly what additional documentation or changes are needed.
Consider obtaining a credit rating
Even a basic rating from a recognised agency would materially improve the product's acceptability. This is a cost/benefit decision but worth exploring if SIPP distribution is a priority channel.
Compile the audited track record
Providers will want to see the fund's performance history, audited by Moore LLP, with clear risk metrics. The longer and more transparent the track record, the stronger the case.
It is worth noting that Small Self-Administered Schemes (SSAS) present fewer hurdles than SIPPs for this type of product. SSAS trustees are typically the company directors themselves, meaning investment decisions are made directly by the members rather than filtered through a third-party provider's investment committee. There is no equivalent capital adequacy surcharge, no provider panel to get onto, and no gatekeeper between the product and the investor.
SSAS may therefore be the more productive initial distribution channel while the SIPP conversation develops.
This document is for internal discussion purposes only and does not constitute financial, legal, or regulatory advice. Product details are based on the draft term sheet (Dillon Eustace, 12 March 2026) and are subject to change. Stephenson Harwood's comments are described as generic, high-level guidance only.
Prepared April 2026.