Financial Options has admitted for the first time that it is facing a six-figure fine from the PIA over the pension review.
The admission comes a month after the 228-member network dismissed as "speculation" suggestions that it could be hit with a record £600,000 fine.
However, last week the network met with the PIA in a bid to lower the amount of the fine, citing mitigating circumstances and track record.
Chairman Mark Blake says: "We expect to be fined but at what level we have no idea. All we can go on is what other companies have got."
Network DBS, which has 545 priority cases, was fined £425,000 in September for failing to progress with the review.
Blake doubts that Financial Options will get confirmation until the new year but expects a "fairly sizeable fine". He says members will not be affected by the fine, which will be paid out of reserves. He dismisses the £600,000 figure as "ludicrous".
The network has 44 priority-one cases and a total of 295 priority cases to complete by the end of December.