Rethinking ongoing advice to deliver client value

What happened?

As the FCA raises the bar on how compliance must be demonstrated, Joe Norburn, CEO of TCC Group (TCC, Momenta and Recordsure), sets out what firms need to do to be ready for 2026. His view, featured by IT Supply Chain, is that firms need to move beyond good intentions towards always-on, data-led evidencing.

He points to increasingly focused regulatory data requests, tougher evidential thresholds and far less tolerance for gaps in audit trails or reliance on manual, sample-based reviews.

Why does it matter?

Firms still operating periodic assessments or relying mainly on human-led controls are likely to struggle as scrutiny intensifies. The message is that documentation created after the fact, or evidence covering only a sample of clients, will increasingly fall short of what the regulator expects.

Who is affected?

Firms delivering an ongoing advice service, particularly those relying on periodic or sample-based reviews rather than continuous evidence of client outcomes.

Key risks

• Reliance on periodic assessments that cannot keep pace with increasingly focused regulatory data requests.
• Gaps in audit trails that leave firms unable to evidence individual client outcomes.
• Sample-based reviews that do not provide full-population visibility of ongoing advice delivery.

Actions to take

1. Assess whether current evidence of ongoing advice delivery is generated continuously, or only produced periodically or on request.
2. Identify where audit trails have gaps and consider how these can be closed as part of everyday processes.
3. Consider how AI-driven analysis alongside human judgement could provide full-population visibility rather than relying on sampling.

Wider implications

The direction set out here reflects a wider pattern across ongoing advice servicing: the FCA’s expectations are moving from firms being able to describe a process to firms being able to prove, for each client, that it worked.

Recommendations

Firms should begin building evidence readiness into everyday processes now, rather than treating it as a periodic exercise, combining automated analysis with human judgement to produce defensible audit trails and clear proof of positive customer outcomes.