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Regulatory change

CP26/10: what it means for your firm

CP26/10 doesn't let you off the hook. It puts you on a bigger one. Here is what the FCA's consultation on ongoing advice charges and annual reviews says, who it affects and what firms should do now. The consultation closed on 22 May 2026. As of 7 October 2026 the FCA has not published its policy statement, so the current rules still apply in full.

Last updated 7 October 2026.

25 Mar 2026

Published

22 May 2026

Consultation closed

Not yet published

Policy statement (checked 7 Oct 2026)

To be set in the policy statement

Implementation

What CP26/10 proposes

CP26/10 proposes that firms charging ongoing advice fees must evidence that clients are receiving the service they are paying for. The blanket annual review requirement goes away. In its place: a duty to review clients at a frequency the firm determines is appropriate, consistent with Consumer Duty.

The firm must document its rationale for each client segment. It must evidence that the chosen frequency reflects the client's circumstances, the complexity of their arrangements, and the nature of the ongoing service. CP26/10 proposes tying ongoing charges to evidenced service. The FCA describes the change as replacing the annual suitability review with periodic reviews based on clients' needs. It has not yet published final rules.

This is not deregulation. It is a shift from prescriptive compliance to outcomes-based evidence. The burden of proof moves from "did you do an annual review?" to "can you justify your review approach for every client segment?"

The part most firms are missing

CP26/10 doesn't let you off the hook. It puts you on a bigger one. Proving ongoing value to every fee-paying client is harder than ticking an annual review box. Firms that treat this as permission to stop reviewing will face the sharpest regulatory scrutiny.

Who this affects

Every firm with ongoing advice clients who aren't being reviewed regularly. The firms most exposed are those with large long-tail segments: clients paying ongoing fees but sitting below the threshold where a full adviser review is commercially viable.

The FCA's review of ongoing suitability reviews at 22 of the largest advice firms found cases where the firm made no effort to deliver the review (FCA finds vast majority of ongoing suitability reviews delivered, 24 February 2025). Under CP26/10, those firms face a harder problem: they would need to evidence the review and the rationale behind their chosen review frequency.

The three options for firms

1. Stop charging

Switch long-tail clients to a non-advised, non-charging arrangement. You lose the recurring revenue permanently. For a firm with 300 long-tail clients, each a client on a low ongoing fee, that recurring income is gone. Illustrative figures.

2. Hire internally

Recruit staff to conduct the reviews. Adds fixed cost (£35,000-£50,000 per head), takes months to hire and train, and creates a scaling problem as the client book grows. One reviewer can handle roughly 200-250 reviews per year. If your long tail is larger, you need more than one. Illustrative figures.

3. Outsource to Pillar

£450 per client reviewed, ex VAT, invoiced monthly as reviews complete. We agree a start date on the first call. Our Client Review Managers work inside your Intelliflo, follow your processes, and generate the evidence the consultation describes. You keep the client relationship and the recurring revenue.

What good evidence looks like

A file note that says "annual review conducted, no changes" shows very little. A stronger file records:

✓Client objectives reviewed and any changes noted
✓Holdings confirmed with the client, any change noted for the adviser
✓Vulnerability indicators assessed using a consistent framework
✓Escalation triggers applied and documented
✓Actions taken or explicitly deferred with reasoning
✓MI aggregated at portfolio level for oversight reporting

Timeline

25 Mar 2026

CP26/10 published

22 May 2026

Consultation closed.

Not yet

Policy statement and final rules. The FCA says it will publish feedback and a policy statement once it has reviewed the responses. No date has been given.

To be set

Implementation period.

What firms should do now

Read the consultation paper. The substance is in chapters 3 and 4. Map your client segments by revenue and review frequency. Identify which segments are exposed. Model the cost of reviewing each segment at the frequency you think the FCA will consider appropriate.

While the policy statement is awaited:

  1. Keep delivering the service each fee-paying client pays for, and record it.
  2. Segment the book by ongoing fee and cost to serve, client by client.
  3. Write down the review frequency each segment needs, and why.
  4. Put the evidence in your next Consumer Duty board report. What the FCA wants that report to show.

Firms that start building their review infrastructure now will transition smoothly when the rules take effect. Firms that wait will pay more to move faster later.

Related reading

Frequently asked questions

Has CP26/10 become final?

Not yet. The consultation closed on 22 May 2026. As of 7 October 2026 the FCA has not published its policy statement or final rules.

Do the current annual review rules still apply?

Yes. Until the FCA publishes final rules and an implementation date, the existing rules on ongoing advice and suitability reviews apply in full.

What should adviser firms do now?

Keep delivering and evidencing the service clients pay for, segment the client book by fee and cost to serve, and set out the review frequency each segment needs, so the firm is ready whichever way the final rules land.

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Don't wait for the final rules

Firms that keep reviewing now will have the evidence on file when the final rules land.

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