Issued in the summer, the s165 survey asked firms detailed questions on areas such as staff resources, number of active clients, diversity within the client base, vulnerable customers, client primary objectives, target markets, the robustness of file checks and governance when business models change.
The survey was designed to paint a picture of the sector, giving the regulator the data it needs to focus supervisory effort where the risks- or opportunities- are greatest, rather than trying to continually monitor everything at once.
For firms, the exercise will also hopefully act as a valuable mirror. If a firm reports very low numbers of vulnerable clients, or a low number of files checked compared with their peers, or no action taken in respect of the retirement income advice review, it should prompt questions about whether enough is being done to meet expectations. Once the survey results are published, they should offer valuable benchmarks for firms who want to compare themselves against the wider industry and prioritise areas for closer reflection. Previously the FCA has indicated that it is likely to focus its attention on the‘ outliers’, that’ s not to say being different to the crowd is a bad thing, it’ s just that justification and evidence of good outcomes may well be expected.
Alongside the survey and Consultation Papers, advisers will also have noticed the FCA becoming more visible: attending industry events, speaking at conferences- including Simplybiz’ s Member Conferences earlier this year-, and engaging directly with advice firms. That greater contact, combined with the survey data, again suggests a shift towards a more informed, targeted and, in some respects, collaborative supervisory approach.
Looking ahead to 2026
If 2025 was about gathering the data and setting the agenda, 2026 is likely to be about what the FCA then does with that information. Firms can expect follow-up supervisory work off the back of the survey, continued scrutiny of ongoing service and fair value, and a sharper focus on vulnerable customers.
At the same time, there should be good news: further steps to simplify rules, refine reporting requirements, and reduce unnecessary burdens in areas including SMCR. With a wider lens, there are likely to be further developments in
Trying to track every consultation, interpret every data request, and anticipate supervisory themes alone would be a full-time job
respect of the Advice Guidance Boundary Review including an attempt to revive the simplified advice concept and a perhaps a more flexible, outcomes based, approach to ongoing service delivery.
What won’ t change is the sheer breadth of moving parts. For most advice firms, trying to track every consultation, interpret every data request, and anticipate supervisory themes alone would be a full-time job. Being clear about what is- and isn’ t- relevant to their business, and where they may need specialist support, will be critical as the regulator moves from information-gathering into action in 2026.
Keep your eye on the Regulatory Planner for regular updates on the evolving landscape, new policy, and what any changes will mean for you and your clients.
As always, our compliance helpdesk is also available to help- you can get in touch with them at compliance @ simplybiz. co. uk, or ring 01484 439120.
December 2025 | 11