Bereavement support under scrutiny for investment firms
In recent months, ongoing advice has moved further into the regulatory spotlight, driven by a combination
01/06/26
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What the FCA’s latest ongoing advice focus means for firms
In recent months, ongoing advice has moved further into the regulatory spotlight, driven by a combination of FCA supervisory work, Consumer Duty expectations and proposed changes to the advice framework. What was once seen as a routine, well-established part of the adviser model is now being looked at more closely – particularly how well it operates in practice.
Ongoing advice has become a core part of firm business models, underpinning both client relationships and revenue. As a result, scrutiny is naturally following. The FCA is placing more emphasis on how firms oversee these services, how consistently they are delivered and whether they genuinely provide value to clients over time.
Moreover, ongoing advice is no longer a supporting component of the proposition – for a large proportion of firms it is the model.
A shift away from process-led delivery
At the centre of this is a move away from activity-led thinking towards a stronger focus on oversight. Historically, much of the emphasis has been on whether key processes have been completed, particularly reviews.
Now the question is broader. Can firms demonstrate that the service they have defined is actually being delivered and continues to meet client needs?
For many firms, this is where the challenge sits. Ongoing services are typically well defined at the point of sale, but oversight over time can become less consistent. Management information (MI), quality assurance and monitoring are not always aligned to provide a clear, reliable view of delivery and outcomes.
From defining ongoing services to evidencing value
This links directly to how firms define their ongoing service. The FCA has been clear that services should be specific, structured and designed for a clear target market. That is not new. How firms evidence this – not just through documentation but through an ongoing demonstration that the service is being delivered as intended, remains appropriate and represents fair value – is an area of important focus for firms.
Rethinking the role of suitability reviews
One of the most visible areas of change is around suitability reviews. Annual reviews have long been the cornerstone of ongoing advice, often acting as the primary mechanism for both delivery and evidence. For many firms, the completion of that review has been treated as confirmation that the service requirement has been met.
The FCA’s CP26/10 consultation proposes replacing the mandatory annual suitability review requirement with a more flexible, periodic approach based on client needs and circumstances. This is not simply a technical change. It signals a broader shift in how ongoing advice is expected to operate.
Rather than relying on a fixed annual cycle, firms will be expected to determine when engagement is appropriate based on the client’s situation, the complexity of their arrangements and how their circumstances evolve over time.
For firms, that raises a more fundamental question. If the annual review is no longer the anchor point, what is?
In many cases, it will be the service’s overall design. Firms will need to think more carefully about how and when clients are engaged, what triggers an interaction and how they monitor whether that interaction is delivering value. That moves ongoing advice away from a calendar-driven model and towards something more responsive and evidential.
The reality of disengaged clients: a growing ongoing advice risk
Alongside this, the FCA has continued to highlight the issue of disengaged clients. Not all clients actively use ongoing services even when they are paying for them. That creates a clear risk. For instance, if engagement is low it becomes more difficult to demonstrate that services are being delivered in a meaningful way, and therefore whether they represent fair value.
The expectation is not that every client must engage frequently but that firms understand where disengagement exists and take appropriate steps in response. That might involve re-engagement strategies, changes to how the service is delivered or in some cases, reassessing whether the ongoing arrangement remains appropriate.
A more outcome-led model of ongoing advice
Taken together, these developments point to a more outcome-led model of ongoing advice. Moving away from evidence that something has been done and towards demonstrating that it has made a difference. This is closely aligned with the Consumer Duty which emphasises good outcomes rather than completed activity.
For firms, this does not necessarily mean a complete redesign of their operating model – in most cases the foundations are already there. The challenge is strengthening how those models are governed, monitored and evidenced.
What does this mean for wealth management and advice firms in practice?
That typically means taking a closer look at how services are defined, how consistently they are delivered across the client base, and whether MI genuinely reflects what is happening in practice. It also means reconsidering whether review cycles and engagement approaches reflect client needs rather than internal processes.
There is a distinct thread running through this topic. Firms will have greater flexibility in how they design and deliver ongoing advice but they will also be expected to provide clearer evidence that what they are doing works.
A natural next step for the sector
For some firms, that will be a natural extension of what they already have in place. For others, it will require a more fundamental rethink of how ongoing services are structured and overseen.
Either way, the direction has been defined and ongoing advice is no longer just about maintaining relationships or completing annual processes. It is about demonstrating, in a structured and repeatable way, that the service being provided continues to deliver value.
For firms working through these questions the priority is often not to start from scratch but to identify where oversight, service design and evidence need to be strengthened. 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.