What’s next after targeted support?

Introduction

The FCA’s targeted support regime is now live, marking an important step in the wider Advice Guidance Boundary Review. As we discussed in our previous article, targeted support gives firms a way to provide ready-made suggestions to groups of consumers with similar needs, without moving into full personalised advice. The aim is to bridge the long-standing gap between generic guidance and fully personalised holistic advice, so that more people can get meaningful help with pensions and investments. 

Targeted support, however, was never intended to be the whole answer. With this in mind, the FCA published CP26/10 in March 2026, setting out its next step proposals to simplify the advice rules, so firms feel more confident offering focused, lower-cost advice services, and more flexible ongoing support. 

What CP26/10 proposes:

Simplifying the advice rules

The headline proposal is a simpler advice framework. The FCA cites feedback that firms have historically struggled to design commercially viable simplified advice models because of the perceived regulatory risk of doing so without considering a customer’s full circumstances. The FCA wants one common set of suitability rules, rather than the complexity of marginally different regimes turning on the product in question. This would involve consolidating the suitability rules in COBS 9 and COBS 9A, removing technical distinctions between advice on products in scope of the Markets in Financial Instruments Directive (MiFID), insurance-based investment products and other life policies and pensions.

Sufficient information

The FCA proposes to replace the requirement for advisers to gather and consider “necessary” information with an expectation that advisers consider “sufficient” information. This proposal is to allow firms to take a proportionate and risk-based approach to information required to deliver good customer outcomes, considering the nature and scope of the advice. It aims to signal clearly that firms are expected to exercise judgement about what information is needed to demonstrate suitability, rather than treating the requirement as an obligation to gather all potentially relevant information. In practical terms, that means a simple recommendation, such as how to invest a lump sum into a mainstream product, should not require the same depth of fact-finding as a more complex or higher-risk recommendation. 

Knowledge and experience

The FCA also wants to reduce barriers for less experienced investors. Firms would not always need a formal assessment of knowledge and experience where the recommended product is aimed at people with little or no prior investing experience and the assessment would deliver no discernible benefit. Firms should take a proportionate approach to considering a client’s knowledge and experience, having regard to such matters as the nature and scope of the service provided. Again, the aim is to reduce unnecessary friction for straightforward advice on mainstream products, where features and risks can reasonably be explained and understood by consumers with little or no experience of investing.

Suitability reports

CP26/10 looks to preserve the current circumstances in which a suitability report is required as far as possible, while moving away from concepts of MiFID and non-MiFID business and making limited consequential extensions. As far as content is concerned, the aim is to reduce defensive reporting primarily serving as a compliance record and instead to encourage concise, consumer-focused reports avoiding repetition from other documents. In terms of timing, the proposal is to replace the current disparate requirements with a single obligation to provide a suitability report before the relevant transaction is concluded for all types of business (except a limited carve-out for certain distance communications).  

Ongoing advice

The FCA is proposing to clarify the rules in relation to ongoing advice to encourage firms to be able to charge for ongoing services linked to earlier advice, even where there is no fresh recommendation every time. It also proposes to move away from a blanket annual review model, so that review frequency can reflect the client’s needs and the product’s risk profile. Similar to the other proposals in the paper, the FCA is seeking to support a broader range of service models, including lighter-touch ongoing support where that is all a client needs. 

Disengaged clients

At the same time, the FCA is proposing to provide guidance on the treatment of disengaged clients, including identifying disengaged clients and potentially stopping collecting fees, all against the backdrop of the Consumer Duty. The proposed guidance is intended to give firms clarity on the FCA’s expectations rather than taking the form of prescriptive rules and may also entail the FCA working with industry to publish examples of good and poor practice. 

Trail commission / professional clients

The consultation also includes two forward-looking discussion chapters inviting initial feedback on the topics of trail commission payable to advisers and commission for non-advised distribution, as well as the suitability requirements that should apply to advice provided to professional clients.

What CP26/10 does not include

What is not changing is also important. The FCA is not proposing to lower adviser qualification standards for providing regulated advice or to relax the adviser charging rules introduced following the Retail Distribution Review.

The FOS

As with targeted support, the FCA recognises that close collaboration with the FOS is crucial in creating an environment in which firms feel able to innovate. The FCA openly welcomes views on whether its approach strikes the right balance between offering firms flexibility in how they offer different tiers of advice and the certainty they need in the context of Ombudsman decision-making. 

Next steps

The overall message from CP26/10 is that the FCA wants to consolidate and simplify the advice rules to provide clarification for firms and promote flexibility and innovation. The FCA of course stresses concurrently that consumer protection should not suffer. For now, these are still proposals, with the FCA consulting until 22 May 2026. The FCA is aiming to publish a Policy Statement in Q4 2026. 

If you have any questions regarding the consultation paper, or the related regulatory framework more widely, please contact Beth Jewell, John Roberts or Tom Dunn.

Written by Beth Jewell and John Roberts

Targeted support is an important step forward but it is only part of the answer – we know consumers need a continuum of support.

https://www.fca.org.uk/publication/consultation/cp26-10.pdf