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08 UCIS and unregulated schemes

UCIS and unregulated schemes: no safety net.

An unregulated collective investment scheme pools money into assets that would not normally be sold to the public — land, lending, property development, renewable energy, storage. The schemes are called unregulated for a reason: the protections that apply to ordinary funds, including FSCS protection, generally do not apply to them.

Last reviewed 12 October 2026Written by The mis-sold investment team at Edward & Amaury SolicitorsLegally reviewed by [CONFIRM: name of the solicitor who reviews this content]

Short answer

Unregulated collective investment schemes are not authorised in the way ordinary funds are and are generally not FSCS protected. A complaint therefore has to be about how the scheme was promoted or recommended: what you were told about its regulation, its risk and its protection, and whether that matched the rules in force.

Indicators only. Not legal or financial advice. Not a prediction of outcome.

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NEMO DAT QUOD NON HABETno one can give what they do not have

01 Is this you?

Tick what fits.

A claim is worth pursuing when the facts line up. These are the facts that matter most for this product. If three or more describe your situation, the checker is worth five minutes.

  • The scheme invested in property, land, lending, energy, storage or something similar.
  • You were told the scheme was low risk, or secured, or asset-backed.
  • You were not told, or not clearly told, that it was unregulated.
  • You believed, or were told, that your money was FSCS protected.
  • An adviser recommended it and was paid for doing so.
  • The valuation of the scheme came from the people running it.
  • The money cannot be withdrawn on the terms you expected.
  • It was held inside a SIPP or an ISA, which made it feel more protected.

02 How it works

How a claim works for this product.

  1. Confirm what the scheme was

    Ask, in writing, for the legal structure of the scheme and its regulatory status. Was it an authorised fund, a company, a partnership, or a trust? Was it a scheme that could lawfully be promoted to someone like you? The answers determine everything that follows, and a firm that cannot answer the question clearly is telling you something.

  2. Find out what the promotion said about regulation

    The rules on how investment schemes may be promoted to ordinary investors have been tightened over time. `[CONFIRM: states the current FCA rules on promoting unregulated collective investment schemes; add the FCA page you relied on to the Sources list before publishing.]` What matters for your complaint is the gap between what the material conveyed about regulation and protection, and what was actually true.

  3. Trace every firm in the chain

    UCIS cases typically involve a promoter, an adviser, a platform or SIPP operator, and the scheme operator itself. Each had a different role and a different level of regulatory obligation. Write down who did what, and for which of them you have documentation. A complaint addressed to the wrong firm wastes months.

  4. Establish whether anyone was authorised

    Where a firm was authorised and gave advice, a complaint to it — and if it fails, FSCS — is a real route. Where nobody involved was authorised for what they did, the practical routes narrow to civil claims against individuals and companies, and those need a solicitor. Check each firm on the FCA Firm Checker.

  5. Be clear-eyed about the money

    There are two different pots of money: what the scheme might return through its own assets, and what a complaint might recover. They are not the same, and progress on one does not mean progress on the other. Get a clear view of the scheme’s own position before assuming an award will follow.

03 The clock

Time limits are the first thing to check.

  • Firm complaint: normally within 6 years of the advice or promotion, or within 3 years of becoming aware of cause to complain.
  • Ombudsman: within 6 months of the final response, normally due within 8 weeks, and only against firms within its jurisdiction.
  • FSCS: only where an authorised firm gave advice or carried on a regulated activity and has since failed. The scheme itself is usually outside the scheme.
  • Court: 6 years from the cause of action or 3 years from the date of knowledge, whichever is later, with a 15-year longstop.
  • Knowledge matters here: in unregulated cases the facts often emerge slowly, through valuations and revaluations. The date you could reasonably have known is a question worth legal advice.
The full time-limit guide

04 The routes

Which route fits your facts.

Complain to the adviser

Concentrate on what you were told about regulation and protection, and whether the scheme was suitable at all for someone in your position.

Complain to the SIPP or platform operator

Where the scheme sat inside a pension or a platform, the operator’s decision to accept it is a separate question with a separate answer.

FSCS

Where an authorised firm failed. Investment claims are limited to up to £85,000 per eligible person, per firm for firms that failed after 1 April 2019, and claims that are only about performance cannot be accepted.

Court

Often the only route left where the parties were unregulated. Take advice early on limitation and on funding, and be sceptical of anyone who promises a recovery.

05 Evidence

Documents to gather.

You do not need everything before you start. But a complaint that names dates, amounts and documents is much harder to answer with a template letter.

  • The scheme documents: prospectus, brochure, terms, trust deed or partnership agreement
  • The adviser’s recommendation and fact find
  • The SIPP or platform application and acceptance records
  • Anything stating or implying that the scheme was regulated or FSCS protected
  • Valuation reports and who produced them
  • Statements of payments in, income paid and current position
  • Fee, commission and introducer disclosure
  • Correspondence about withdrawals, redemption or suspension

06 Questions

Questions people ask about this product.

What does unregulated actually mean here?

It means the scheme is not authorised in the way an ordinary fund is, so the protections built around authorised funds — including FSCS protection and the ombudsman route against the scheme — generally do not apply. It does not mean nobody can be held responsible; it means the responsibilities sit with the people who promoted or recommended it.

Can I complain if I was told it was FSCS protected?

Yes, and that statement is central. FSCS publishes what it does and does not cover, and it is clear that some investment products are not protected. The gap between what you were told and what was true is the complaint.

Is it different if the scheme was inside a SIPP?

The pension wrapper does not make the investment regulated. It does add a firm — the SIPP operator — whose own decision to accept the asset can be examined separately.

Why do these cases take so long?

They usually involve more firms, more documents and often a failed underlying asset, and several processes run at once: the scheme’s own position, a complaint against an adviser, and possibly a civil claim. That is a description of the shape of the work, not a promise about any outcome.

Can I get a compensation estimate from the checker?

No. We do not produce compensation figures anywhere on this site, because a figure needs the full file, the correct comparison, and someone accountable for the calculation. The checker tells you which checks fired, which routes may fit, and what to gather.

What should I do first?

Gather the documents, run the checker, and put a written question to the firm that recommended the scheme asking what it told you about regulation and protection. That question alone often reveals more than any research.

Sources

Every rule, limit and deadline on this page comes from the official sources below. Each was read on the date shown. Where we could not verify a rule against the official text, we have left a visible instruction to confirm it rather than describing it from memory.

MIS-SOLD INVESTMENT / CLAIM CHECKER

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