What happened?
A recent Financial Ombudsman Service decision has drawn attention to the risks of DIY SIPP arrangements, particularly for customers displaying signs of vulnerability such as gambling addiction. Writing in FT Adviser, TCC’s Head of Advisory Practice, Gary Maude, set out firms’ safeguarding obligations towards customers taking a DIY approach in the Consumer Duty era.
Why does it matter?
Consumer Duty does not treat a self-directed or execution-only proposition as a reason to step back from identifying and supporting vulnerable customers. The Ombudsman’s decision is a reminder that firms retain safeguarding obligations even where customers are making their own choices.
Supporting sources
Frequently asked questions
Does Consumer Duty apply to DIY or execution-only SIPP customers?
Yes. Consumer Duty applies regardless of whether a customer is advised or self-directed, and firms retain obligations to identify and support customers showing signs of vulnerability.
What risk did the Financial Ombudsman Service decision highlight?
It highlighted the risks of DIY SIPP arrangements for customers displaying signs of vulnerability, such as gambling addiction, and firms’ safeguarding obligations towards them.
- FCA remuneration reform explained: what CP26/27 could mean for firmsAnalysis & Perspectives · September 2, 2026
- IBS Intelligence: Why financial services firms face growing AI governance scrutinyAnalysis & Perspectives · September 2, 2026
- FCA CP26/28: What the AIFM regime reforms mean for wealth managers and firmsRegulatory Horizon · September 2, 2026
- Will Value for Money assessments change how advisers compare pension providers?Regulatory Horizon · September 2, 2026
- Pensions & Retirement IncomeTCC helps pension providers, retirement specialists, advisers, platforms and consolidators strengthen retirement income governance, evidence customer outcomes and manage regulatory risk. Our specialists support firms with retirement income reviews, ongoing servicing assessments, Consumer Duty programmes, DB transfer reviews, vulnerability frameworks, remediation projects and compliance monitoring across the customer lifecycle.
- Wealth Management & Financial AdviceTCC helps wealth managers, financial advisers, networks, platforms and consolidators strengthen compliance, evidence customer outcomes and manage regulatory risk. Every engagement is designed to deliver practical improvements, stronger governance and regulator-ready evidence. For more than 25 years, we have helped FCA-regulated firms navigate regulatory change, supervisory reviews and business growth.
