What the FCA’s latest ongoing advice focus means for firms

What happened?

Ongoing advice has moved further into the regulatory spotlight, driven by FCA supervisory work, Consumer Duty expectations and proposed changes to the advice framework.

The FCA’s CP26/10 consultation proposes replacing the mandatory annual suitability review with a more flexible, periodic approach based on client needs and circumstances, rather than a fixed calendar cycle.

Alongside this, the regulator continues to highlight the issue of disengaged clients who pay for ongoing services but do not actively use them.

Why does it matter?

The central shift is away from activity-led thinking, where completing a review was treated as confirmation the service requirement had been met, towards demonstrating that the defined service is actually being delivered and continues to meet client needs.

If the annual review is no longer the anchor point, firms need another way to determine when engagement is appropriate, based on complexity and how a client’s circumstances evolve.

Low engagement makes it harder to demonstrate that a service is being delivered meaningfully, which in turn makes it harder to evidence fair value.

Who is affected?

Wealth management and advice firms whose business model relies on ongoing advice services are most directly affected, since scrutiny is following the revenue this model generates.

Firms with clients who pay for ongoing services but rarely engage face the most immediate pressure to show they are managing that risk.

Key risks

• Relying on a completed annual review as proof that the service requirement has been met.
• Management information, quality assurance and monitoring that are not aligned to give a reliable view of delivery.
• Disengaged clients whose lack of interaction undermines evidence of fair value.
• Review cycles and engagement approaches that reflect internal process rather than client need.

Actions to take

1. Review how your firm defines its ongoing service and whether that definition is genuinely being delivered.
2. Check that MI, quality assurance and monitoring are aligned to give a consistent view of delivery and outcomes.
3. Identify disengaged clients and consider re-engagement strategies or changes to how the service is delivered.
4. Prepare for CP26/10 by designing triggers for client engagement based on need rather than a fixed annual date.

Wider implications

This points to a more outcome-led model of ongoing advice, in line with the Consumer Duty’s emphasis on good outcomes rather than completed activity.

For most firms this does not mean redesigning the operating model from scratch, but it does mean strengthening how that model is governed, monitored and evidenced.

Recommendations

Take a closer look at how consistently your ongoing service is delivered across the client base, and whether MI genuinely reflects what happens in practice.

Reconsider whether review cycles and engagement approaches reflect client needs rather than internal process, ahead of any change to the annual review requirement.

TCC Group supports firms in reviewing ongoing advice models, assessing whether services are operating as intended and helping build the governance, monitoring and practical frameworks needed to demonstrate value with confidence. Get in touch today to learn how we can help.