At intelliflo’s Innovate 2025 event this week, a spotlight was cast on one of the most urgent issues facing financial services firms: the growing regulatory pressure to deliver – and prove they’ve delivered – ongoing advice services to their clients.

Presented by TCC’s Strategic Regulatory Director, Jason Wintie, alongside TCC and Recordsure’s Chief Product and Commercial Officer, Garry Evans and Claire Bell, Head of Regulatory Risk at Attivo, the session laid bare both the risks and the opportunities facing advice firms.

In a nutshell, ongoing advice is no longer something firms can manage in the background. The FCA is watching closely and the time to act is now.

Ongoing advice concerns

Jason opened the session by explaining that the FCA’s concerns around ongoing advice aren’t new. For years, the regulator has warned against clients paying for services they might not actually receive. But in early 2024, things escalated.

In February, the FCA issued a data request to the 22 largest firms, asking them to report the number of clients due for a suitability review, the number that received it and the number of cases in which fees were refunded because the review didn’t occur. Firms suddenly faced a very clear expectation: if you’re charging for a service, you need to deliver it; if you don’t, you should refund those fees.

A second request followed in October of that year, this time delving deeper into the quality of the advice. The FCA wanted to know whether clients’ attitudes to risk were reassessed, whether their personal circumstances and financial goals were reviewed and updated. These weren’t just data points; this motion hinted at a regulatory standard that’s becoming more defined and more demanding.

Mixed signals or clearer direction?

Then, in February 2025, the regulator published its findings from the review. Some in the industry took it as a green light, as the FCA noted that suitability reviews were delivered in around 83% of cases and stated that the issues weren’t “systemic.” It even softened its language slightly, suggesting that missed reviews wouldn’t always require refunds.

But others read between the lines. The underlying message was clear. Firms need to be able to provide evidence of the delivery of ongoing advice as part of their business-as-usual approach and also going back to 2018. The review can’t just happen. It must be documented, measured and meet clear standards.

For many firms it was a realisation that their processes and records simply weren’t good enough. In fact, several firms have already been subject to section 166 reviews, and remediation work is ongoing across the sector.

What to expect in 2025

While some had hoped the February review would bring clarity, it actually confirmed that the FCA’s focus on ongoing advice is far from over.

The regulator is expected to continue its review of the original 22 advice firms and broaden its supervision to include many more. It has also signalled its intention to review the ongoing advice services rules entirely in 2025, which means changes are coming. And it’s not just the regulator that firms should be thinking about. Claims management companies have already started circling, and they’re paying close attention to this space.

What the regulator wants to see

So, what do good ongoing advice service reviews look like in the eyes of the FCA? Firms need more than just a diary reminder system. They need a robust, well-documented process that ensures reviews are completed on time, that client information is current and that outcomes align with their needs and financial objectives.

The expectation is that firms can clearly demonstrate that they’ve reassessed clients’ risk profiles and capacity for loss and that they’ve delivered tailored, relevant recommendations. Importantly, this has to be done consistently, with the appropriate evidence on file. Beyond that, compliance must be incorporated into the business, not just an afterthought. Ongoing advice should be monitored in real time, integrated into operational processes and included in governance and board-level reporting.

Firms also need to be proactive about when a service should stop. If a client can’t be contacted or if it becomes clear that ongoing advice isn’t adding value, the expectation is that firms will step in, stop the service and refund fees where appropriate.

Shifting from reactive to proactive

After Jason’s regulatory walkthrough, Claire Bell from Attivo took to the stage to share how her organisation has approached these challenges internally. Her message was that change is possible, but it requires focus, leadership and a genuine willingness to evolve.

This was followed by Garry Evans showing us what the future can look like by introducing the role of predictive AI in ongoing advice. By automatically flagging where reviews are overdue or incomplete, predictive AI tools like Recordsure AI offer a new level of oversight and a real opportunity to improve both compliance and efficiency. Rather than replacing human judgment, the technology augments it. This enables firms to catch risks earlier, make better decisions and deliver better outcomes for their clients.

Turning pressure into progress

The FCA’s growing interest in ongoing advice isn’t just a regulatory challenge – it’s a chance for firms to strengthen client relationships, reduce risk and modernise their operations. Expectations are rising, but so are the tools, processes and insights available to firms that want to stay ahead.

Whether you’re looking to strengthen your processes, improve your evidence trail or explore how AI can drive smarter, more efficient reviews, TCC can help.

Contact us today to begin developing your future-proof approach to ongoing advice.