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The FCA’s latest survey of the financial advice sector shows that 88% of retail clients now receive ongoing advice. As a sector, we understand the benefits that a well-designed ongoing advice service can bring to clients, which is why it has become such a central part of firms’ business models.
In publishing its findings, the FCA again highlighted the importance of effective oversight of ongoing services.
One of the more nuanced observations was that, on average, larger firms reported reviewing a smaller proportion of ongoing advice files than smaller firms, defined as those with five or fewer advisers. At the same time, the survey found that 19% of small firms did not undertake any reviews of ongoing advice.
The FCA noted that firms could benefit from reviewing a greater proportion of ongoing advice files, alongside testing service delivery more consistently and making better use of management information to monitor customer outcomes.
Getting these fundamentals right is one of the most effective ways firms can strengthen client outcomes, while also supporting more sustainable advice models.
Simplifying advice rules brings ongoing services into sharper focus
These findings were published just a month before the FCA released its long-anticipated consultation paper, which simplified the pensions and investment advice rules. Ongoing advice services feature prominently, with a full chapter dedicated to the topic.
The FCA confirms that it has discussed ongoing advice services extensively with industry stakeholders
The consultation paper opens by highlighting the scale of ongoing advice across the market: around 80% of adviser charge revenue relates to ongoing advice charges, delivered to approximately 3.7 million clients.
The FCA also references the findings from its multi-firm work on ongoing financial advice services, published in 2025, which continues to inform its thinking in this area.
The FCA confirms that it has discussed ongoing advice services extensively with industry stakeholders and is now consulting on three specific areas.
1. Clarifying the requirements for ongoing services
The FCA proposes to clarify that firms can offer and charge for services related to advice, whether or not a new personal recommendation is provided. Where they do so, firms will need to ensure that those services are clearly defined, delivered to a specified target market and represent fair value for clients.
A key proposal is the removal of the prescriptive annual suitability review requirement currently set out in COBS
2. The frequency of suitability reviews
Another key proposal is the removal of the prescriptive annual suitability review requirement currently set out in COBS. In its place, firms providing an ongoing advice service would be subject to a more flexible requirement to carry out periodic suitability assessments.
Under this approach, firms would be expected to determine the most appropriate review frequency based on an assessment of customer needs and circumstances, while continuing to meet their obligations under the Consumer Duty.
3. Disengaged clients and follow-up work
In relation to disengaged clients, the FCA is not proposing to introduce prescriptive rules. Instead, it intends to issue new Handbook guidance clarifying its high-level expectations for how firms should meet their Consumer Duty obligations when dealing with clients who are not engaging with ongoing services.
Joe Norburn: Rethinking ongoing advice to deliver client value
Alongside the proposed new Handbook guidance, the FCA has also said it intends to work with the industry to publish examples of good and poor practice. It has made clear that it welcomes feedback from firms, particularly where further clarity would be helpful.
Both the consultation paper and the FCA’s Consumer Investments Regulatory Priorities Report reference a multi-firm project examining what action firms have taken since the regulator published its findings on ongoing advice services in February 2025.
That review is already underway, and the questions the FCA asks within it provide a good indication of the action it expects firms to have taken since its earlier observations.
What the FCA is now asking firms to evidence
The questionnaire issued to firms is structured into eight sections. It begins by asking whether firms have commenced, or already carried out, an assessment to identify whether ongoing services were delivered to clients between 2018 and 2025. Firms are then asked to explain the approach they have taken to evidence service delivery.
Where firms have identified issues, the FCA asks further questions about the nature of those findings
These questions underscore the FCA’s expectation that firms should, at a minimum, have started reviewing the delivery of ongoing advice services dating back to 2018.
The questionnaire goes on to explore the findings of any reviews undertaken and whether issues have been identified. Where firms have identified issues, the FCA asks further questions about the nature of those findings, including whether any customer contact has already taken place or is planned.
Additional questions focus on remediation and redress. Here, the FCA asks whether firms have identified a need for remediation and whether any redress exercise has been undertaken. Firms are also asked how many clients were included in the review, how many received redress and the total amount of redress paid.
The questionnaire concludes with questions on complaints handling and disengaged clients, including whether firms have a documented disengagement process in place.
Taken as a whole, the FCA’s latest survey reinforces the importance of ongoing advice – both for clients and for firms
Where this leaves ongoing advice
Taken as a whole, the FCA’s latest survey reinforces the importance of ongoing advice – both for clients and for firms.
The FCA’s Regulatory Priorities and subsequent consultation paper underline its continued focus on this part of the market and set out proposals for how the framework may evolve. The current multi-firm work, meanwhile, confirms the extent of the retrospective review the FCA expects firms to have undertaken.
Whether that involves updating policies, strengthening oversight or reviewing historic delivery, ongoing advice remains as important to the sector as it has ever been.
Joe Norburn is CEO of TCC Group
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