The CP26/10 consultation closed on 22 May 2026. The FCA will publish a policy statement in Q4, and later than that if the volume of responses is heavy. Between now and then, nothing in the rulebook changes. The annual suitability requirement that applied in March applies through the autumn and into next year. A lot of firms have read the consultation as a signal to ease off the long tail. That reading will cost them.
What has actually changed
Nothing has. CP26/10 is a proposal. The move from a blanket annual review to a segment-justified periodic cadence is the direction of travel, not the law in force. Until the policy statement lands and any transition window completes, a firm charging an ongoing fee owes the same annual suitability obligation it owed before the consultation opened. Treating a consultation paper as if it were a final rule is the error that does the damage.
Three things that bite before Q4
The board report is due 31 July. The Consumer Duty annual board report has to be seen and approved by the governing body by 31 July 2026. It has to evidence that clients paying for ongoing service are receiving it. A firm that quietly stopped reviewing its long tail in anticipation of CP26/10 has to write that down. The board signs a document that records fees charged and reviews not delivered. That is not a position any director wants to put a name to six weeks from now.
Enforcement is live. The FCA published its first Enforcement Watch newsletter on 28 January 2026. It confirmed six open Consumer Duty investigations, most of them on fair value: whether the price a client pays is matched by the service delivered. The regulator has written to around 20 of the largest advice firms asking for data on ongoing service where fees continue after the initial advice. The supervisory tool of choice is a redress programme imposed as a condition of permission. That cost lands on the firm, not the regulator.
The evidence gap compounds. Every month a sub-threshold client goes unreviewed is a month that has to be explained later. The distance between now and the policy statement is at least two quarters. A firm that pauses reviews now is digging a two-quarter hole in its evidence file at the exact moment the FCA is asking to see that file.
Why the relief never arrives
The firms reading CP26/10 as permission to do less have it backwards. A longer review cadence is harder to defend than an annual default, not easier. The firm has to evidence, segment by segment, why a client can safely wait longer between reviews, and it has to monitor the periods in between rather than rely on the review itself. The work moves from running the review to defending the decision not to. For a firm with hundreds of clients below the threshold that costs more to service than it generates, that defence has to be built client by client. None of it is lighter work.
What firms should do now
Keep reviewing the long tail. Do not pause. Capture the evidence as the review happens, so the board report writes itself and the audit trail exists before anyone asks for it. The clients below your commercial review threshold are exactly the cohort that gets dropped when a firm eases off, and exactly the cohort the fair-value work is built around.
This is the case for outsourcing. A structured review delivered by trained staff, working inside the firm's own systems and under its own brand, costs a fraction of adviser time and produces the same compliant evidence trail. It keeps the long tail current through the CP26/10 transition instead of letting it lapse. When the policy statement lands in Q4, the firm that kept reviewing is ready for whatever cadence the final rules set. The firm that waited has two quarters of silence to account for.