Why ongoing advice is facing a regulatory reset

What happened?

The FCA has replaced more than 40 portfolio letters with nine Regulatory Priorities reports addressed directly to boards and chief executives, setting out a single, coherent view of its supervisory focus. The Consumer Investments report frames sector success as engagement, education and long-term thinking rather than risk avoidance.

Alongside this, the FCA is consulting on simplifying pensions and investment advice, proposing greater use of simplified, individualised advice for consumers with more straightforward needs, to sit alongside comprehensive advice and targeted support.

Why does it matter?

In a Consumer Duty environment, ongoing advice can no longer be justified by tradition or routine. The FCA’s priorities make clear that supervision is increasingly focused on whether services continue to meet evolving client needs, deliver fair value and adapt as circumstances change.

Many ongoing advice models were designed for a different regulatory era, with fixed annual reviews and standardised service definitions once treated as sufficient evidence of good practice. Those features are now being re-examined against actual client behaviour, outcome data and evidence of responsiveness.

Who is affected?

The changes are most relevant to wealth management and financial advice firms that offer ongoing advice services, particularly those relying on fixed review cycles or standardised service definitions rather than client-specific triggers.

Key risks

• Ongoing advice justified by habit or inherited structure rather than evidenced client benefit.
• Fair value assessments treated as periodic exercises rather than dynamic ones.
• Gaps between formal reviews where changes in client circumstances, vulnerability or risk tolerance go unnoticed.
• Governance and monitoring frameworks that exist on paper but do not feed back into service design.

Actions to take

1. Review how the firm decides when ongoing engagement is genuinely required, rather than defaulting to fixed cycles.
2. Test whether fair value assessments are updated dynamically as client engagement and circumstances change.
3. Strengthen how changes in client circumstances between formal reviews are identified and addressed.
4. Ensure outcome monitoring, complaints and disengagement data feed back into decisions about service structure.

Wider implications

The FCA is not seeking to discourage innovation or constrain access to advice; it is testing whether firms can deliver more flexible, proportionate services while still evidencing good consumer outcomes. Firms that can explain why their model works, for whom and with what safeguards are generally finding supervision constructive.

Recommendations

Firms should reframe ongoing advice around outcomes rather than activities, use triggers and data to inform engagement, and treat fair value assessments as a continuous discipline rather than a periodic report.