The FCA’s new consultation proposes moving to flexible, periodic reviews. Some are calling it a revolution. I’d call it a rebrand – with more complexity attached, not less.

If you’ve been anywhere near LinkedIn in the past few weeks, you’ll have seen hot takes like these ones:

“Annual reviews are dead!”
“FCA frees advisers from tyranny of the twelve-month cycle!”

The suggestion appears to be that financial advisers are about to get a significant burden lifted from their shoulders. But I’d urge a pause before getting carried away. The reality is considerably more nuanced. And for many firms, the practical implications of the FCA’s latest proposals represent more work, not less.

What the FCA actually said

In February 2025, following a review of 22 of the largest advice firms covering seven years of data, the FCA published its findings on ongoing advice services. The headline was broadly positive:

• Suitability reviews were being delivered in around 83% of cases, with a further 15% attributable to clients declining or not engaging.
• In fewer than 2% of cases had firms failed to even attempt a review – and those firms will need to consider redress.

FCA Ongoing Advice Review – Key Numbers (February 2025):

• 83% of cases: suitability review delivered
• 15% of cases: client declined or did not respond to the offer of a review
• <2% of cases: firm made no attempt to deliver a review – likely requiring redress
• Firms asked to conduct retrospective reviews back to 2018
• 22 largest advice firms in scope, with further follow-up work planned across the wider market

Then, in March 2026, the FCA published Consultation Paper CP26/10: Simplifying the Pensions & Investment Advice Rules.

The centrepiece proposal was all around replacing the prescriptive requirement for annual suitability reviews with a more flexible obligation to carry out reviews on a “periodic” basis, with frequency determined by reference to the client’s needs, circumstances, attitude to risk, and the complexity of their investments. The consultation closes on 22 May 2026, with a policy statement expected by the end of the year.

At the same time, the FCA is proposing to consolidate COBS 9 and COBS 9A into a single common framework, remove certain prescriptive rules where Consumer Duty already provides equivalent protection, and open a discussion on legacy trail commission arrangements.

The noise vs the reality

Here’s where I would challenge the excited marketing posts proclaiming the death of the annual review.

Let’s start with the most obvious point. If you ask any sensible financial professional – or indeed any reasonably informed individual – whether it’s a good idea to go more than 12 months without reviewing your financial situation, the answer is almost universally no. Life changes. Markets move. Tax rules shift.

The idea that relaxing the formal cadence somehow translates into better client outcomes needs quite a lot of justification before it holds up. More flexibility, yes. A genuine improvement to client experience? That’s a much harder argument.

More freedom means more complexity, not less

The deeper issue is what “flexibility” actually requires in practice. Under the current rules, firms operate on a broadly uniform 12-month cycle. It’s not perfect. Anyone who has spent time reviewing annual review reports knows they can be formulaic, compliance-driven documents that don’t always serve the client particularly well. And it’s not just the report itself – here at Evotra we spend time helping firms nail the end-to-end process itself far more than we do the written report. But the fixed cycle has the considerable virtue of being simple to administer and simple to audit.

Moving to a variable cycle, firms would now need to:

Model service propositions against different review frequencies
If you’re going to offer some clients annual reviews and others biennial or quarterly ones, you need to articulate clearly – and compliantly – why. Even assuming you’re still sticking to a fixed frequency (just not an annual one), that means building out differentiated service propositions, pricing those propositions to reflect their actual cost of delivery, and satisfying Consumer Duty fair value requirements for each tier.

Justify individual review periodicities
The FCA’s proposed framework requires firms to set review frequency by reference to client characteristics, risk profile, and investment complexity. That’s a documented, evidenced, client-by-client judgement call. For a firm with thousands of clients, this is a significant operational undertaking.

Evidence delivery against a non-standard schedule
The obligation to demonstrate that you are doing what you said you would do does not go away. If anything, a variable schedule makes this harder to systematise, not easier. At least with an annual cycle, your compliance team knows exactly what to look for and when. A bespoke schedule per client is a materially more complex thing to monitor and evidence.

And here is perhaps the most pointed observation: most firms still struggle to produce genuinely high-quality, client-centric annual review documentation on a fixed 12-month cycle. If that’s the starting point, what grounds do we have for confidence that moving to a variable, client-needs-led cycle is going to produce better outcomes? The underlying process quality challenge doesn’t disappear because the cadence changes.

To summarise, most firms struggle with formulaic annual review reporting on a fixed 12-month cycle, so what exactly makes anyone think that moving to a variable cycle is going to make things any easier?

The retrospective obligation isn’t going anywhere

It’s also worth being clear about something the celebratory LinkedIn posts tend to gloss over. The FCA’s forward-looking consultation on periodic reviews sits alongside a very live, very current obligation to look backwards. The FCA has made it explicit that all firms, not just the original 22 in the multi-firm review,  should assess whether they can evidence delivery of ongoing advice services going back to 2018. That’s eight years of records. And the FCA has signalled it will conduct further supervisory work to assess how firms have responded, including whether appropriate remedies are being applied.

Major firms have already set aside significant provisions in response to this retrospective work. The new rules, whenever they arrive, don’t change the historic position at all.

Note: If you think your firm may need help evidencing your historic ongoing advice, we can definitely help you. Have a read of this article to find out more:

What firms should actually be doing

None of this is to suggest that CP26/10 is unwelcome. Simplifying COBS, removing redundant prescription, and aligning the advice framework more coherently with Consumer Duty are genuinely sensible developments. And there are real circumstances – highly engaged clients with straightforward situations, for instance – where a more tailored review cadence might genuinely serve them better. And with the continuous advancements in AI across the industry, you never know what will be possible just around the corner.

But the strategic response for a wealth management firm right now is not to start planning how to reduce the frequency of client contact. It is to engage seriously with the consultation (the deadline is 22 May 2026), to start modelling what differentiated service propositions would actually look like under the proposed framework, and to continue (urgently) the work of ensuring historic ongoing advice delivery can be properly evidenced.

The FCA is giving the industry more flexibility. But with flexibility comes accountability for the choices you make. The compliance and evidencing burden doesn’t reduce; it evolves. And the firms that navigate this well will be those that treat it as a design challenge. How do we build service propositions and review processes that genuinely work for clients and can be evidenced compliantly – rather than an opportunity to do less?

Five things to do right now

1. Audit your historic records back to 2018. Don’t wait for the FCA to come to you. Identify any clients who were not offered a review and assess whether redress is appropriate.

2. Review your MI on review delivery. The FCA has been explicit about the risk of “tick-box” attestations. Can you genuinely evidence that reviews took place and met a reasonable quality bar?

3. Address persistently disengaged clients. The FCA expects firms to consider whether an ongoing service is in the client’s best interest if they have repeatedly declined engagement – and to act accordingly, including considering refunding charges. We covered this in our recent article all about how to design a smarter annual review process in your CRM system.

4. Respond to CP26/10 before 22 May 2026. The final rules will govern your service model for years to come. Engage with the consultation and make sure the FCA hears from practitioners about the real operational implications.

5. Model your service propositions under the proposed framework. If periodic reviews become the rule, you need differentiated propositions with coherent pricing and fair value justifications – ideally before the Policy Statement lands in Q4 2026.

On a final note, we should add that this article reflects the views of Evotra and is intended as commentary on regulatory developments, not as legal or compliance advice.

However, we are experts in technology, data and business process. So if anything in this article has made you stop and think for a moment, do reach out to us to see how we can help set you up for success. You can call us on 020 3410 1966 or email hello@evotra.co.uk

Written by: 

Sally Merritt, Co-founder and Chief Executive Officer