Whilst there is no doubting the importance of ongoing advice services and regular suitability reviews to ensure that both investments held and the ongoing service remain suitable for clients’ current needs, risk profile and objectives, it is acknowledged that all clients have their own bespoke situations and many have varying needs at different stages of their lives.
Throughout an individuals’ natural life cycle, financial goals, risk tolerances and capacity for loss will change. At some stages, such as moving into drawdown, managing an IHT issue or dealing with a potential vulnerability, more frequent suitability reviews may be necessary whilst for those with simpler, low-risk investments or younger consumers in the accumulation phase of investing for retirement, less frequent reviews might be a better fit to their actual needs.
In February 2025, the FCA published findings from its multi-firm review of ongoing advice, that showed that 15 % of clients declined or did not engage with offered reviews, supporting a shift toward a more flexible, client-centric approach.
It is also acknowledged that annual reviews can be resource intensive for firms. The recent FCA
information request( Understanding the advice market: financial advice firms survey 2025) findings indicated that since 2021, despite the number of authorised firms falling by 15 %, adviser numbers have remained steady at around 31,000. Whilst the steady adviser number is encouraging, this alone does not help reduce the acknowledged‘ advice gap’. With this proposal to allow a more flexible approach to ongoing suitability reviews and the introduction of technological support, we are hoping that it will both better meet the needs of individual clients, whilst also providing much needed resource to provide financial advice to a broader client base.
Furthermore, the FCA has intimated that a more flexible review model could also possibly lower costs for consumers who may otherwise have been priced out of important ongoing services. Under Consumer Duty, we would expect that any new or revised service offering would be subject to fair value considerations.
What does this mean in practice?
● Proposals are still at consultation stage, but if implemented, firms will need to define review frequencies across different client segments.
● Firms can start to consider drivers for less frequent reviews( e. g. lower-risk portfolios, simpler needs) and triggers for maintaining annual or more frequent reviews.
● Where an annual review remains appropriate, it should continue as the standard approach.
● Robust“ know your customer” data – including clear, measurable, time-bound objectives – will become increasingly critical in determining review frequency and service models.
● Firms will need to adapt controls and oversight frameworks to manage the added complexity of more flexible review schedules.
● In practice, many firms are likely to take a cautious approach, waiting for clearer market direction and regulatory expectations before making significant changes.
In a recent Simplybiz poll, we asked members how they felt about moving to a more flexible ongoing advice service. 65 % of the advisers who responded said they were‘ broadly supportive’ of the proposals with 25 % currently‘ undecided’. Asked whether firms would look to change their current ongoing service offering should the FCA make these changes, the response was a little more cautious with 33 % stating yes whilst 40 % indicating that they remained undecided.
These responses seem to be an indication that it is still quite a new concept and further clarity is required to support decision making within the adviser community. It should also be noted that advisers have raised concerns in respect of the ombudsman and ensuring that they are aligned to the FCA expectations.
It seems sensible that the timing and frequency of the review should sit with the adviser firm as they are the ones who are closest to the customer and have a greater understanding of the clients needs.
It is however, worth re-affirming at this point that this is only at proposal stage so it is important that firms do not reduce the frequency of periodic suitability reviews to less than annual until final rules are confirmed by the FCA towards the end of the year, which we look forward to seeing.
June 2026 | 21