The FCA ongoing advice review: can you evidence every client who paid?

The FCA’s ongoing advice review asked firms one question: did every client who paid for an ongoing service receive it, and can you prove it? The answer the regulator wants is client by client, back to 2018, and a firm-level percentage does not give it.

The rest of this article sets out what the FCA asked, what it said firms should do, and what evidence holds up.

What the FCA asked

On 15 February 2024 the FCA wrote to around 20 of the largest advice firms. It asked for three things: the number of clients due a review of the ongoing suitability of their advice, how many received that review, and how many paid for ongoing advice but had their fee refunded because the review did not happen. It also asked whether firms had assessed their ongoing services in response to the Consumer Duty.

The FCA said the selection was not based on concerns with those firms. It was collecting the data “to assess what, if any, further regulatory work it may undertake in this area.”

What it found, and what it told every firm to do

The FCA published its findings on 24 February 2025. It looked at seven years of data from 22 firms and said it did not view the issue as systemic. It also said its sample was not representative of the market.

The instruction that matters for your firm is the next part. The FCA said all firms “should read our findings and take the necessary action.” Specifically, firms should:

• check whether they can evidence delivery of every service their contracts or the rules require
• consider contacting clients proactively to assess whether harm was caused, looking back to 2018
• consider redress where a review was not attempted, which the FCA said is “likely” to be due
• consider fair value under the Consumer Duty, PRIN 2A.4, for the period since July 2023

The FCA listed “inadequate record-keeping to make sure firms can evidence delivery of their services” as poor practice. Good practice was the mirror: records that let the firm evidence delivery where it was provided.

The test is a reconciliation, not a policy

Crudely speaking, the FCA is asking you to put two lists side by side. One list is every client who paid an ongoing fee in a given year. The other is every client who had a suitability review in that year, with the record to prove it.

Most firms hold both lists. They rarely hold them in the same place. Fees sit in the back office or with the platform. Review records sit in the client file, the diary, the adviser’s notes and the shared drive. A policy document that says “we review every client annually” is not evidence. The match, client by client, is.

Where the lists do not match, there are three kinds of gap:

1. Paid, no review attempted. This is where the FCA expects redress to be likely.
2. Paid, review offered and declined. Redress is less likely. The FCA said that where a client has declined for several years, the firm should discuss whether the service is still in the client’s best interest.
3. Paid, review held, no record. The review happened and the file cannot show it. Under the FCA’s own poor-practice list, that is still a failure of record keeping.

Why this does not go away under CP26/10

CP26/10, published on 25 March 2026, proposes “replacing the annual suitability review with periodic reviews based on clients’ needs.” The consultation closed on 22 May 2026. As at 3 November 2026 the FCA page shows no policy statement yet.

A move to periodic reviews changes how often a review is due. It does not change the question. If a client pays for an ongoing service, the firm still needs to show what the client received for that fee. A needs-based frequency arguably makes the evidence harder, because the firm must also show why the frequency it chose fits each client. We set out the detail in CP26/10 and periodic reviews.

What holds up

The evidence that answers the FCA’s question has four parts, held per client:

• the ongoing fee taken, by year, from the back office or platform
• the review due date the firm’s own service terms set
• the review record: date, who held it, the suitability outcome, where it is filed
• where no review took place, the reason: declined, no response, or not attempted

With those four on one line per client, the reconciliation is a sort on one table, not a file audit. Without them, the firm is reconstructing years of history from diaries and inboxes, which is the position the FCA’s poor-practice list describes. The same file stands up to a Section 165 request, which we cover in Your annual review file wouldn’t survive a Section 165 request.

Where Pillar fits

Pillar gives no regulated advice and never decides what a client should do. Two parts of what we do bear on this.

Pillar Lens reads a firm’s Intelliflo data and puts every client on one line: ongoing fee, allocated cost to serve and assets under management. It shows which clients cost more to serve than they pay and where service records are missing. That gives you the first list, per client, in one place.

The client review service runs reviews for the clients you choose, starting with those below your profitability threshold. Your brand, your systems, your clients. We take the preparation, the meeting, the write-up and the filing, in your own systems, so the second list builds as reviews happen.

The reality is that behind every line of that reconciliation is a client who was told they would hear from their adviser. The FCA’s question is whether they did. If you would like to see how the match looks on your own book, talk to us.

Frequently asked questions

Sources: FCA, Ongoing financial advice services, published 24 February 2025, read 27 October 2026; FCA requests information from firms about delivery of their ongoing advice services and the Consumer Duty, published 15 February 2024, read 27 October 2026; FCA, CP26/10: Simplifying the pensions and investment advice rules, last updated 1 June 2026, read 3 November 2026. General information for regulated firms, not regulatory or legal advice.