The FCA's review of ongoing advice services found that 17% of firms are not delivering annual reviews to clients paying ongoing fees. Section 165 data requests are already landing on firms' desks. If your files cannot evidence what was discussed, what changed, and what action was taken, your firm is exposed.
What the FCA expects
Consumer Duty requires firms to deliver fair value, act in the client's best interest, and avoid causing foreseeable harm. For ongoing advice, that means regular contact with every client paying an ongoing fee. Not just the top tier. Every client.
The evidence requirements are specific. The FCA expects to see a documented file note for every review. That note should record what was discussed, whether the client's circumstances have changed, whether their risk profile is still appropriate, and what action was taken or recommended.
A calendar entry or a generic letter does not count. The FCA wants to see substance, not process.
Where firms are falling short
Most firms deliver annual reviews to their high-value clients. The problem is the long tail: clients generating £200 to £800 per year in ongoing fees. The cost of an adviser-led review exceeds the revenue the client generates. So the review does not happen.
This creates a compounding problem. Every year without a review adds another 12 months of regulatory exposure. If the FCA asks for evidence of client contact and the file is empty, the firm cannot justify the ongoing charge.
What CP26/10 changes
The FCA's consultation paper CP26/10 proposes linking the right to charge ongoing fees directly to the delivery of annual reviews. If a firm cannot evidence that it conducted a review, it may lose the right to charge for that period.
This is not a theoretical risk. The consultation closed in 2026 and final rules are expected within 12 months. Firms that are not already building a review capability for their long-tail clients are behind.
What firms should do now
Segment your client book. Identify every client paying ongoing fees who has not received a documented review in the past 12 months. Quantify the revenue at risk. Then decide whether to build internal capacity or outsource the review function.
Pillar exists to solve this problem. We conduct structured, FCA-compliant annual reviews for your long-tail clients, inside your systems, using your processes. Every review is documented. Every outcome is recorded. Your compliance team gets the evidence the regulator expects.