The Big Lift: Why Bulk Migration is the Bridge to AI-Ready Wealth Platforms

A few weeks ago, a colleague asked me to outline the advantages of replatforming clients using bulk data transfer (aggregated assets) vs a batched, client-by-client approach. That’s a great question, as legacy system platform migrations accelerate bulk data migrations, which have significant benefits for larger books. Clients benefit because they don’t experience any perceptible transition time. Firms benefit from data cleanup requirements that yield a pristine, structured dataset, serving as the essential foundation for AI readiness that was previously buried under layers of technical debt. Before diving into bulk migration, let's recap two other approaches:

Client-by-Client Migration

Favoured by advisers and typically conducted as part of a client review. Client disturbance is minimised, as the adviser is in complete control of communications and tailors them to suit individual needs. This approach is best for:

Vulnerable Clients: Changing financial providers can be confusing, and a hand-held process ensures these clients understand exactly what is happening and feel supported, mitigating conduct risk

High Net Worth Clients: They expect a concierge service which reinforces the personal relationship and allows for the careful handling of valuable relationships.

Complex Instruments: e.g. illiquid assets, offshore bonds, or legacy products with unique crystallisation events that standard automated transfer gateways cannot process.

The Trade-off. Highest level of control and client care, Vs adviser effort and overall timeline. It is unscalable for mass-market books but is the optimum approach for high-risk or high-value segments and complex instruments.

Batched Migration

Involves moving groups of client cohorts with the same characteristics in distinct tranches. Unlike client-by-client migration, this is an industrialised pipeline that aims to reduce the adviser's effort and timeline by designing each migration tranche to accelerate the transfer of assets as a single event in a compressed timeframe. Typically, 6-8 weeks end-to-end if the process is well designed and managed. Batched migration allows firms to test and learn by migrating low-risk cohorts first (e.g., wrappers with simple investments and GIA accounts with no CGT liabilities). The key to making this approach viable for firms is automating client communications, data cleanup, and loading into the transfer gateway of choice and in a nutshell, taking the heavy lifting away from the firm.

Data from the Origo Transfer Index, published in October 2025, for pension cash transfers: 12 days overall and 10.7 days for simpler transactions where the ceding provider is in complete control and does not depend on third-party providers to execute the transfer.

Bulk Migration: the scaled industrialised solution that involves the novation of the entire book of business at an aggregated asset level at once (or in very large tranches), usually without requiring individual client signatures for every transfer. This relies on negative affirmation as the preferred consent approach to ensure the predictability of timelines and the percentages of clients moved. If you required 5,000 clients to provide explicit consent before moving them, the response rate could be as low as 70%, forcing you to run multiple platforms simultaneously, which is commercially and operationally unviable.

Advantages:

Speed: Moving thousands of accounts over a single weekend minimises the "limbo" period where clients cannot trade.

Uniformity: Everyone lands on the new platform at the same time.

The FCA may permit a negative affirmation that the move is not detrimental to the client. The easiest case to justify is when there is no change to the investment strategy, the costs are the same or lower, or the future of the current investment platform is uncertain. Scenarios such as ongoing service failures, profitability, changes in ownership, etc., are all supportive factors.

FCA permission for a bulk migration is not required, but you must engage with your FCA supervisor 3–6 months in advance. They will want to see your migration plan, risk assessment, and communication strategy. The evidence required on request includes:

Firms' Terms of business must permit a change of custodian/platform.

The no-detriment analysis shows that the new platform charges are equal to or lower than the existing charges, and that the investment strategy is consistent. There may be a cash interest uplift to add to the client value benefit if the receiving platform retains less – or none- of the interest income on cash balances.

The golden source data plan that evidences data integrity, book cost accuracy, transaction history, and investment performance.

The communication pack must provide clear opt-out instructions and a reasonable response timeline. Good practice is to allow a 60-day window for chase-ups and handling of gone-away clients.   The exit must be cost-free if they do not wish to be migrated.

The rollback plan is documented, and a tested procedure for reversing the migration if it fails on the go-live weekend.

The reconciliation approach that identifies any breaks in the integrity of the data extract, transformation and load pipeline.

Bulk vs Batch: ETL vs Gateways

The engines that enable bulk migration are not the Origo and Equisoft transfer gateways. These are replaced by an Extract, Transform and Load (ETL) utility. Gateways are designed as point-to-point connectors that move data at a client/investment level – without altering it. The bulk scenario is entirely different due to the complexities of the data pipeline, which requires pulling data from multiple sources, applying cleanup and transformation rules, and loading it into the target platform. They are optimised for ease of use, replacing development with configuration, improving speed, and enhancing auditability. Historically, these were bespoke/highly customised developments. During a bulk move, there are three key processes.

Cleansing, augmenting, transforming and moving the data from the ceding platform (and other data sources) to the receiving platform’s database. The hard part.

Registering the assets from one custodian to another (one aggregated instruction per fund/asset to the fund manager informing of a change of custodian).

Disaggregation. Once the assets are reconciled at the unit level, the receiving platform applies them to the individual accounts and reconciles the units and valuations at the client level.

Whilst gateways aren't used for the move itself, they may have a role pre- and post-migration:

Pre-migration pending transfer completion. To enable the book to be frozen before the migration weekend.

Post-live residuals. Sometimes, a small number of assets cannot be moved via the bulk process and are typically transferred in the weeks following the migration.

The good news is that ETL utilities have evolved significantly over the last decade, and tools like the Finio Data Hub, from Sprint Technologies, provide a specialised integration hub designed specifically for the UK wealth management industry. I recall the Aegon/Cofunds migration programme and the effort, time, and cost required to build an ETL pipeline involving multiple consultancies and specialist contractors. ETL utilities now have pre-built connectors that use AI to map, validate, transform, and reconcile data. Development effort is replaced by configuration, and easy-to-use dashboards surface audit trails/exceptions.

 Historically, when performing a bulk migration, the temptation is to move only opening balances because it's technically easier. However, migrating the full transaction history and performance data creates a much richer and continuous dataset. ETL utilities take the heavy lifting out of what was once a significant complexity. Also, Consumer Duty requires firms to prove they are acting in the client's best interest throughout the entire lifecycle of the relationship. If you only migrate current balances, you lose the context of why the client invested. Without historical data, you cannot demonstrate a portfolio's long-term suitability. If a client complains three years from now about a loss, and your new system doesn't show the original purchase price, the market conditions at the time, or the 5-year performance trend, you will struggle to defend your past advice.

Why Bulk is Better

Ultimately, a well-executed bulk migration is better for the client, as it ensures a seamless transition in which their financial history is preserved and their tax positions are protected. It happens as one event, typically over a weekend.

For the firm, the prize lies in establishing a pristine dataset as a clean foundation for AI adoption, transforming client data from a liability into a strategic enabler.

In the next article, I will dive into the detailed timeline and processes that support a bulk data migration. In the meantime, if you have any questions, drop me a message. 

Contact: dave.howard@wealthtechpros.com