A statement on its website said it had been working to review agent records, but there was no suggestion it had been completed.
Under the new regulation, fund managers are required to ensure their commission payments are in line with rules on legacy business and they are not paying trail to advisers on business which has been subject to new advice since December 31 2012.
The company said: “The forthcoming renewal commission payment for the six-month period ending April 2013 will be the first made since the RDR became effective. The additional checks Henderson has needed to make means that the commission payment will occur on this occasion approximately three weeks later than typically has occurred in the past.
“This does not mean that future commission payments will occur later than usual. Henderson apologises for any inconvenience that may be caused by the timing of commission payments on this occasion."