CP26/10 landed on 25 March 2026. The consultation closes 22 May. The FCA is proposing to scrap the blanket requirement for annual suitability reviews and replace it with a new obligation: periodic reviews at a frequency the firm determines is appropriate for each client.
On first reading, this looks like a win. Less prescriptive. More flexibility. Fewer reviews to conduct.
That reading is wrong.
What the consultation actually proposes
The FCA wants firms to assess, for each client segment, how often a review is needed to meet Consumer Duty obligations. The firm must document its rationale. It must evidence that the chosen frequency is appropriate given the client's circumstances, the complexity of their arrangements, and the service they are paying for.
The mandatory annual review goes away. What replaces it is a duty to justify your review cycle, per segment, with evidence.
For high-value clients with complex arrangements, firms will still review annually or more. Nothing changes there. The impact falls on the long tail: clients paying ongoing fees below the threshold where full adviser engagement makes commercial sense.
The trap for long-tail clients
Under the current rules, the requirement is clear: annual review. Firms either do it or they don't. Under CP26/10, the firm has to decide what "appropriate" means for its lower-revenue clients and defend that decision to the FCA.
If you decide that clients paying £400 per year only need a review every three years, you need to show why. You need evidence that the client's circumstances are stable. You need records showing how you monitor for changes between reviews. And if a client's situation changes and you miss it because you chose a three-year cycle, the liability sits with you.
The firms most at risk are the ones that see CP26/10 as permission to stop reviewing. The FCA is doing the opposite: it's making firms own the decision and the consequences.
What this means for ongoing fees
CP26/10 also tightens the link between ongoing charges and ongoing service. If a client is paying for an ongoing advice service, the firm must demonstrate the client is receiving that service. The review is the primary evidence.
Firms that reduce review frequency for long-tail clients need to either reduce the fee (and take the revenue hit) or evidence that the client is still receiving value through other means. Neither option is straightforward.
The simplest path is to continue reviewing these clients regularly and document it properly. The question is who does the reviewing and at what cost.
The operational reality
A firm with 500 ongoing clients might have 350 in its long-tail segment. Under CP26/10, it needs to: define the client segments, set review frequencies for each, document the rationale, conduct the reviews at the chosen frequency, evidence every review to Consumer Duty standard, and monitor between reviews for changes that might trigger an earlier review.
That is more operational complexity than an annual review cycle, not less. It requires segmentation logic, scheduling systems, structured review templates, monitoring processes, and a team to execute it.
Most firms don't have this infrastructure. They were already struggling to conduct annual reviews. CP26/10 doesn't solve their problem. It reframes it.
The timeline
The consultation closes 22 May 2026. The FCA typically publishes its policy statement 3-6 months after consultation closes, with an implementation period after that. Final rules could take effect in late 2027.
That sounds distant. It isn't. Firms that wait for final rules before acting will face a compressed implementation window. Firms that start building their review infrastructure now will transition smoothly.
What firms should do now
Read the consultation paper. It is 67 pages. The substance is in chapters 3 and 4. Respond to the consultation if your firm has a view on the proposals.
Map your client segments by revenue, complexity, and review frequency. Identify where the gaps are. Work out what it would cost to review each segment at the frequency you think is appropriate. Compare that cost to the ongoing fee income from each segment.
For most firms, the maths will confirm what they already know: the long-tail segment cannot be reviewed profitably using adviser time. The choice is to stop charging, hire internally, or outsource.
How Pillar fits
Pillar conducts structured reviews for your long-tail clients inside your systems. Per-review pricing. No setup cost. Every review generates the evidence CP26/10 will require: objectives, vulnerability, escalation, actions, MI. Your advisers stay focused on high-value work. Your firm retains its ongoing fees.
We built the model inside a live IFA firm with 578 clients. 90% of reviews needed no adviser involvement. The 10% that did generated revenue on escalation.
If you are thinking about how to handle periodic reviews under CP26/10, we should talk.