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In response to rivals' criticism against the insurer for stating it would proactively sell to orphaned clients, Stephen Gay, director of distribution development of Aviva, said the insurance giant was recognising providers could no longer pass the buck simply to IFAs for looking after clients.

He said: "Clients with strong relationships with their IFAs we are not concerned about. It is those who do not feel they are owned by anybody and have not been spoken to by anybody for a long time that we need to closely look at.

"We have got to come to some sort of consensus in our industry between distributors and product providers as to what the mechanism will be to make sure customers get the service they deserve and who will provide it to them economically.

"With treating customers fairly there is a responsibility on advisers to make sure people are properly looked after. As product providers we can no longer say it is none of our business if this does not happen."

Mr Gay's comments came as it unveiled research conducted with Association of IFAs members that showed only 54 per cent think they are likely to still be trading as a financial adviser following implementation of the retail distribution review.

A quarter said they were unlikely to be trading once the retail distribution review measures come in and a further 21.5 per cent were unsure what they would be doing in 2012.

Three quarters of advisers said they wanted to retain their independent status if they continued to work as an adviser. Only 6 per cent were considering a move to trading as a non-independent adviser.

Gary Bottriell, chartered financial planner of Dorset-based IFA Bottriell Adams, said: "It is a rather convenient interpretation of TCF. If a policyholder is attached to an active IFA then it is the IFAs' responsibility to look after them.

"It is not Aviva's responsibility to check up on whether the IFA is giving a proper service or not.

"Aviva has been a very successful direct general insurer. If they want to try that in the life and pensions market then good luck to them - they must have very short memories. But they want to be careful about stepping on IFAs' toes.

"How would they go about assessing the relationship between an IFA and their client?"