Looking back at 2025, it’ s hard to escape the sense that it was a year defined by transition. Not seismic regulatory upheaval, nor dramatic single moments of change, but a continual shift in how the sector operates, evolves, and delivers value. Much of what has happened last year won’ t fully show its impact until further into 2026 and beyond, but the foundations were unmistakably being laid this year.

The shift of Consumer Duty from rules to culture

The FCA’ s continued focus on embedding Consumer Duty shaped much of the regulatory agenda. Whilst the big areas of focus in 2025 for the regulator – and therefore for advisers – were the reviews on Retirement Income Advice and Ongoing Advice Services, looking ahead to 2026 this will evolve through the delivery of the Advice-Guidance Boundary Review- more specifically, targeted support and simplified advice.

The Ongoing Advice Review was particularly telling. Although early findings were more positive than expected, with the majority of firms demonstrating strong delivery, around 17 % of cases still showed gaps in fulfilling ongoing service commitments. The FCA has been clear that this is only the beginning of its work in this area; it intends to expand the review further, using the initial results and a data-led approach as a launch point for a deeper look at how firms deliver, evidence, and document ongoing value.

What struck me most, though, was the nature of the FCA’ s questions last year. The Section 165 data request wasn’ t limited to product selection, suitability checks, or record-keeping. It also asked about business models, future plans, client profiles, and operational processes. The question set tells its own story: Consumer Duty is no longer simply a regulatory expectation- it’ s a cultural expectation, centred on whether firms have embedded consumer-centric thinking into the core of how they operate.

Tom Hegarty, CEO Simplybiz

8 | The Adviser Online