● How much will it cost the business, and how will this be reflected in terms of an ongoing charge to clients.
● How the delivery of the service proposition will be tracked and monitored.
● What will happen if clients don’ t engage with the annual review.
You might also have a segment of your client bank that doesn’ t require an annual review, so you’ ll need to consider whether you continue to work with these clients on a transactional basis, hearing from them only when they need further support, or whether they’ ll be offered an admin only service. As part of MiFID II requirements, firms are able to offer an admin only service where this relates to advice given previously, however given the focus Consumer Duty has put on price and value, advisers offering this option will need to think about what tangible services they are able to offer to clients that can demonstrate‘ fair value’. The FCA states that consumers should receive fair value, with a reasonable relationship between price and overall value. Consumer Duty requires firms to assess and evidence what benefits clients receive from the service. clients and can be clearly evidenced as delivering value. Whether you offer one level or several, in person or online, each element should have a clear purpose, a fair cost, and a measurable outcome. By taking a structured, transparent approach, firms can demonstrate good value, maintain profitability, and strengthen long-term client relationships- all whilst staying firmly aligned with the spirit of Consumer Duty.
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Business Consultancy can help and support you in designing / reviewing your ongoing service proposition please email BC @ simplybiz. co. uk if you would like more information or to discuss your individual firm requirements.
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It is important to give clients choice and ensure you are confident that what is offered to them is easy to understand, gives clear value, is fully delivered and evidenced.
Data and MI are key focuses for the regulator, so it is important that you can track the delivery of ongoing services to clients, through a back-office or compliance system. Technology systems can help streamline your advice process, so it’ s important you chose the right system that you can adapt to your company needs and one that offers seamless MI and Data outputs. Simplybiz members can use the Navigator digitised compliance solution to log review activity and evidence this with key management information. Under Consumer Duty the services you offer to clients should be reviewed on an ongoing basis and delivered at least annually under MiFID II requirements. You also have to meet the firm’ s contractual obligations under the Service Proposition agreed. As part of Consumer Duty annual monitoring the data should be able to tell you what is working and what is not so you can review and amend appropriately to ensure that regulatory and contractual requirements are met.
Importantly, firms should also ensure they have a disengagement policy in place, to ensure that clients are not being charged for an ongoing service when it is not being taken up by the client.
Of course, ultimately, there isn’ t a one-size-fits-all answer to building an effective ongoing service model- what matters most is that it reflects the needs of your
March 2026 | 5