Why it’s time to rethink your approach to ongoing advice services

What happened?

In a session presented by TCC’s Strategic Regulatory Director, Jason Wintle, alongside TCC and Recordsure’s Chief Product and Commercial Officer, Garry Evans, and Claire Bell, Head of Regulatory Risk at Attivo, speakers set out the risks and opportunities facing advice firms on ongoing advice.

The FCA’s concerns are not new: for years it has warned against clients paying for services they might not receive. In February 2024, it issued a data request to the 22 largest firms, asking for the number of clients due a suitability review, the number that received one, and the number of cases where fees were refunded because the review did not take place. A second request in October 2024 probed the quality of reviews, including whether attitudes to risk and personal circumstances were reassessed.

The FCA published its findings in February 2025, noting that suitability reviews were delivered in around 83% of cases and that the issues identified were not systemic.

Why does it matter?

While some in the industry read the February 2025 findings as reassuring, the underlying message is that firms need to be able to evidence the delivery of ongoing advice as part of business as usual, going back to 2018. A review cannot simply happen; it must be documented, measured and meet clear standards.

Several firms have already been subject to section 166 reviews, and remediation work is ongoing across the sector. The FCA is expected to broaden its supervision beyond the original 22 firms and has signalled its intention to review the ongoing advice services rules in 2025, meaning further change is likely. Claims management companies are also paying close attention to this area.

Who is affected?

Wealth management and financial advice firms that charge for ongoing advice services, and the compliance and advice teams responsible for suitability reviews and client evidence.

Key risks

• Insufficient evidence on file to demonstrate that a suitability review took place and what it covered.
• Client risk profiles and capacity for loss that are not regularly reassessed.
• Ongoing advice services that continue after they have stopped adding value to the client.
• Claims management company interest in firms that cannot evidence delivery of ongoing advice.

Actions to take

1. Put in place a documented, repeatable process that ensures reviews are completed on time and client information is current.
2. Reassess clients’ risk profiles and capacity for loss and record tailored, relevant recommendations at each review.
3. Monitor ongoing advice in real time and incorporate it into governance and board-level reporting, rather than treating it as an afterthought.
4. Stop the service and refund fees where appropriate if a client cannot be contacted or ongoing advice is no longer adding value.

Wider implications

The FCA’s growing interest in ongoing advice is not only a regulatory challenge; it is a chance for firms to strengthen client relationships and modernise their operations. Predictive tools, such as Recordsure AI, can flag where reviews are overdue or incomplete, adding a layer of oversight that supports, rather than replaces, human judgment.

Recommendations

Firms should combine a backwards-looking review of past practice with a forward-looking, sustainable process for ongoing advice, supported by clear evidence and, where helpful, predictive tools that highlight overdue or incomplete reviews.