The annual suitability review is on its way out: what CP26/10 means for ongoing advice services

For the last decade, the annual suitability review has been the spine of ongoing advice. Every retail client, every twelve months, whether anything in their life had changed or not. CP26/10 wants to bin that.

The FCA's consultation paper, published on 25 March 2026, proposes to replace the annual suitability review with periodic reviews based on each client's needs. Responses close on 22 May 2026, with a Policy Statement expected by the end of the year.

Most coverage has focused on the COBS 9 / 9A consolidation and the new "sufficient information" wording. Both matter. But the bit that will actually rewire how firms operate day to day is the shift away from a fixed annual cycle.

What CP26/10 actually proposes

Strip out the legalese and the headline changes for ongoing services are these:

The current rule that requires a suitability assessment at least once a year for MiFID investments and insurance-based investment products goes away. In its place, firms decide the right review cadence for each client, based on the client's needs, characteristics and objectives, their attitude to risk and ability to bear loss, and the nature, complexity and risk profile of what they hold. For retail clients, the cadence also has to be consistent with your Consumer Duty obligations.

The FCA is also consolidating COBS 9 and 9A into a single framework, swapping "necessary" for "sufficient" information when assessing suitability, introducing one "attitude to risk" concept (with explicit confirmation that you don't need a complex psychometric tool to evidence it), and retiring FG 17/8 by building its proportionality principles directly into the Handbook.

Two things are not changing: adviser charging stays, and qualification requirements stay. So this isn't RDR-level disruption to the business model. It's a rewrite of how you evidence ongoing value.

Why this is harder than it looks

On the surface, "review when the client needs it, not on a fixed date" sounds like a gift. Less work for clients who don't need an annual sit-down. More capacity for the ones who do.

In practice, you've traded one prescriptive rule for a much more demanding judgement call. Twelve months as a default was easy to operate and easy to evidence. A risk-based, client-by-client cadence is neither.

A few questions every firm will need to answer:

How do you decide who gets a review every six months and who gets one every two years? It can't be gut feel from the lead adviser. The FCA will expect a documented methodology that ties cadence to the factors in the rule, which makes client segmentation a regulatory workflow as much as a commercial one.

How do you spot trigger events between scheduled reviews? A client retiring, inheriting, divorcing, or changing risk appetite has always mattered. Under a flexible cadence it matters more, because there's no annual safety net.

How do you handle disengaged clients without a Consumer Duty problem? CP26/10 explicitly flags this. A client who hasn't replied to your last three review invitations is a Consumer Duty issue, not an admin one.

How do you evidence to a future supervisor that your cadence delivered good outcomes for each cohort, not just the firm overall?

This is fundamentally a data and workflow problem before it's a compliance one.

What good preparation looks like

Three things firms can do now, before the policy statement lands:

One: segment your client book by review need, not just by AUM. Most firms still segment commercially. Under CP26/10 the relevant segmentation is by complexity, vulnerability, life stage and product mix. Some firms will find their A clients need less frequent reviews than their C clients. That's uncomfortable, but it's where the rule is heading.

Two: write down your cadence logic. If your answer to "why does this client get an 18-month cycle and that one a 9-month cycle" lives in the head of one adviser, that's a problem. The methodology needs to be on paper, applied consistently, and reviewable.

Three: build the trigger-event muscle. Between scheduled reviews you need a way to surface the changes that should pull a client forward in the queue. Most firms today rely on advisers remembering, or on clients getting in touch. Neither is good enough when the annual default is gone.

This is where the right systems pay for themselves. Tracking review cadence per client, flagging trigger events from data already in your CRM, evidencing Consumer Duty outcomes per cohort, and producing the audit trail when a supervisor asks. None of that is impossible to do in spreadsheets, but it gets painful fast as the book grows.

The bigger picture

CP26/10 is part of a broader FCA pattern. Targeted support went live in April. The Advice Guidance Boundary Review is winding down to its final pieces. Consumer Duty is moving from "are you implementing it" to "can you evidence outcomes." The direction of travel is consistent: less prescription, more principles, more responsibility on the firm to think and to document.

For well-run firms this is good news. The annual review has been a blunt instrument for years, and most advisers know it. CP26/10 gives you permission to spend more time with the clients who need it, less with the ones who don't, and build a service that fits each segment.

The work is making sure your processes, your data and your evidence are ready when the policy statement lands. Q4 2026 sounds far away. It isn't.

Glimzer is the CRM that gives UK financial advice firms their time back. If you'd like to see how we help firms run a clearer, more joined-up ongoing service, book a 20-minute walkthrough.