The FCA Just Made Advice Rules Simpler. Here's What Changes for Your Firm.

The FCA's just published a consultation that could cut the compliance admin at your firm. Here's what's actually changing, and what it means for how you work.

On 25 March 2026, the FCA released Consultation Paper CP26/10 on simplifying the pensions and investment advice rules. The headline: consolidate overlapping regulations, ditch the annual suitability requirement, and reduce the paperwork. For a small firm, that sounds promising. But the detail matters.

What's Actually Changing

Right now, advisers live with COBS 9 (advice to retail customers) and COBS 9A (pension transfer advice). The FCA's first move is to merge them into one framework. One set of rules to know. One training cycle. Less time wondering which rule applies to which client.

Next, the suitability requirement. Currently, you have to carry out a fresh suitability assessment every 12 months for certain ongoing services. The FCA's proposing to replace that fixed annual cycle with periodic suitability reviews. In practice, that means you'll review suitability based on your clients' needs, not just because the calendar says so.

Then there's the suitability report itself. Currently, you have to include quite a bit of detail. The FCA's simplifying this. Reports should include only useful, relevant information. Skip the boilerplate. Skip the bits the client doesn't need to see. This one's straightforward: less paperwork, clearer reports for clients.

There's also a clarification on ongoing service fees. If you provide ongoing advice linked to an earlier recommendation, you can now charge a fee for that ongoing service. It won't be treated as a new recommendation. That's a relief for many firms, because it removes an ambiguity that's caused confusion on fee structures.

What Stays the Same (And Why It Matters)

Don't expect the FCA to loosen the reins on suitability itself. You still have to demonstrate that advice is suitable. You still need to know your client. You still need to hold and understand their information. The removal of the annual requirement doesn't mean suitability checks vanish. It means you're not on a forced timetable. That's subtly different.

This matters because some firms might assume the changes give them licence to review less often. They don't. The FCA's just shifted the trigger from "once a year" to "when circumstances warrant it." If you get that wrong, the consequence is the same: unsuitable advice, client harm, and regulatory action.

What You Should Do Before 22 May

The consultation closes on 22 May 2026. That's seven weeks to feed back to the FCA if you want to, but honestly, most firms won't. Here's what's worth your attention instead.

Start documenting your current suitability review process. How do you decide when to review? What triggers a reassessment in your firm right now? When the rules change, you'll need to replace the "annual" trigger with something more intentional. Having a clear process now means you're not scrambling to invent one in summer when the rules are finalised.

If you use a template for suitability reports, audit it. Cut the padding. Ask yourself: does the client need to see this? If the answer's no, consider taking it out. The FCA's putting the onus on firms to think about what advice actually needs to be recorded. Doing that exercise now means you'll be ahead when the new rules land.

And if you've been sitting on a fee structure review because of ambiguity around ongoing service fees, don't wait. Get your fees clear now. By the time the new rules land, you'll know whether you need to adjust what you charge.

The Bigger Picture

This isn't happening in isolation. The FCA's also rolling out the targeted support regime from 6 April, opening up a new category of regulated advice for firms that want to serve clients who don't need full personalised recommendations. The direction is consistent: simpler rules, broader access, more flexibility.

The FCA's philosophy here is obvious. They're tired of watching firms treat compliance as a series of rituals. They want advisers to think about why rules exist, not just how to tick the boxes. That's a healthier regulatory approach. It also means firms that've built genuine processes around client review and suitability end up better off. The paperwork side gets simpler. The thinking side stays the same.

The consultation itself is clear, but the final rules will be embedded across multiple sourcebooks. If your firm's relying on memory and educated guessing to stay compliant, now's the moment to rethink that. Tools that help you record the thinking behind recommendations and keep a clear log of what you've reviewed and when are becoming less nice-to-have and more essential. Not because the FCA will force you to use them, but because firms that make compliance intentional rather than accidental will have an easier time proving it.

The 22 May deadline is worth a quick calendar mark. But don't use it as an excuse to delay your own thinking. The simpler rules are coming. Get ready now.