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Introduction to Ongoing Financial Advice: Are Annual Reviews Changing?
Ongoing financial advice is under review as the FCA considers whether a fixed annual suitability review remains the right approach for every client. The direction of travel is towards more flexibility, but that does not reduce the need for advice firms to show that clients receive a useful service for the charges they pay.
For advisers and planners, this is not simply a compliance issue. It is a chance to reconsider what clients need between meetings, how often their circumstances should be reviewed and how the value of advice is explained throughout the relationship.
What is ongoing financial advice?
Ongoing financial advice is the support a client receives after the initial recommendation has been made. It can include suitability reviews, portfolio monitoring, planning updates, access to an adviser, changes to investments and help when a client’s circumstances change.
The exact service should be set out clearly in the client agreement. A client needs to understand what they are paying for, how often contact will happen, what will trigger a review and how they can change or stop the service if it no longer meets their needs.
For many clients, the annual review is only one part of the relationship. Their real value may come from having someone who can help them make sense of a redundancy, inheritance, pension decision, business sale, illness or change in family circumstances.
Why are annual reviews changing?
Current rules have required many firms to carry out a suitability review at least annually for relevant business. The FCA has proposed replacing the fixed annual requirement with periodic reviews based on a client’s needs, circumstances and the type of service provided.
FCA consultation paper CP26/10 proposes greater flexibility in how firms design and deliver ongoing services, including periodic rather than fixed annual reviews.
That does not mean firms can collect a charge and wait for clients to make contact. The FCA’s focus remains on good outcomes, fair value, consumer understanding and support. Clients must receive the service they have agreed to pay for. Firms reviewing growth should also have a clear pipeline generation strategy so new client acquisition does not distract from delivering the promised ongoing service.
Ongoing financial advice may therefore become more tailored. A client with stable circumstances may need a different review pattern from someone drawing retirement income, preparing for a business sale or dealing with complex family wealth planning.
What are the FCA proposals trying to solve?
The FCA has been examining whether clients who pay for an ongoing service actually receive it. Its review found that most suitability reviews were delivered, but also highlighted weaknesses in some firms’ records, oversight and client engagement.
A fixed annual meeting can become a process rather than a useful conversation. If nothing has changed, a client may see little value in repeating the same discussion. Equally, a client’s position can change significantly shortly after an annual meeting and require support much sooner.
Ongoing financial advice should respond to the client’s real position rather than the firm’s diary cycle. The proposed flexibility gives firms more scope to design services around risk, complexity and life stage. It also creates a greater need to evidence why the chosen approach delivers fair value.
Firms will need to show that they understand their client base. A review schedule should make sense for the service, the client’s needs and the risks involved. A vague promise of contact “when needed” will not provide enough clarity. Clear opportunity qualification can also help firms establish early whether a prospect genuinely fits the ongoing service being offered.
What could a better review service look like?
A useful review looks beyond investment performance. It asks whether the client’s objectives, income needs, risk tolerance, family situation, tax position and plans have changed. It also checks that the client understands the plan and knows what action to take next.
For a retired client, ongoing financial advice may involve more frequent contact around withdrawals, spending, tax and market movements. For a younger accumulation client with straightforward finances, the service may focus on planning milestones, pension contributions and support when a material change occurs.
Clear client conversations matter here. Corporate sales training for teams can help advisers explain the purpose of reviews without relying on technical language or a standard meeting script.
Firms should also make it easy for clients to tell them when something changes. Reviewing where prospective clients fall out of the advice journey can highlight stages where unclear communication or unnecessary friction prevents suitable clients from progressing. A simple prompt before a review can uncover issues that may otherwise remain hidden, such as a new job, divorce, health concern, house move or planned retirement.
How should firms demonstrate value?
Value is not proven by sending a review pack or holding a meeting. The client should be able to understand what the firm has done, what decisions were considered, what has changed and what the next steps are. Good records matter for both the client and the firm.
Ongoing financial advice should have a defined service proposition for each client group. A firm may offer a different service to a client in drawdown, a business owner, a professional building wealth or a family preparing for intergenerational planning. The service and charge need to match. For higher-value or more complex relationships, key account planning can help firms identify where more tailored contact and support may be justified.
Corporate sales skills training can help client-facing teams make their service easier to understand, especially when discussing the value of planning, ongoing support and adviser charges.
Review client feedback, attendance, complaints, cancellations and outcomes. These measures can show where clients see value and where the service may be unclear. Consumer Duty requires firms to take those findings seriously and act when a problem is identified.
What happens when a client does not engage?
Some clients will decline a review, postpone it or fail to respond. That does not automatically mean the firm has failed, but the firm should be able to show that it made reasonable attempts to deliver the agreed service and explained any risks of not engaging.
Keep records of contact attempts, the service offered, what the client decided and any information that may affect suitability. A client who actively chooses not to take up a review should still understand how to contact the firm if their circumstances change.
Ongoing financial advice arrangements should also explain what happens after repeated non-engagement. Firms need a fair, consistent process for deciding whether to continue the service, move the client to another arrangement or stop charging for a service that is no longer being used. As technology develops, firms should also consider how AI and jobs may change administrative work without removing the need for adviser judgement and accountability.
These conversations need care. B2B corporate sales training can help teams ask clear questions, listen properly and explain next steps without making clients feel pressured.
How should advice firms prepare now?
Start by reviewing each ongoing service proposition. Check that client agreements describe the service accurately, that charges match the work delivered and that the review approach is suitable for the people receiving it. Do not assume that one model works for every client.
Map the full client journey from onboarding to review, including contact between meetings. Identify where clients receive useful support and where the service becomes an administrative routine. Ongoing financial advice should be designed around the outcomes clients need, not only around compliance deadlines.
Firms should prepare advisers for more meaningful value conversations. Corporate sales training programmes can support consistent client communication when teams need to explain advice, fees and planning outcomes clearly.
Finally, monitor the FCA consultation and any final rules. The proposals may change before implementation. Firms that already understand their services, records and client outcomes will be in a stronger position to adapt. Business-owner clients may also need reviews when external pressures such as supply chain disruption affect company cash flow, valuations or personal financial plans.
Frequently asked questions about ongoing financial advice
What is ongoing financial advice?
Ongoing financial advice is the continuing professional support a client receives after the initial recommendation or financial plan has been established. It can include investment and suitability reviews, financial planning updates, access to an adviser, retirement and tax discussions, and support when circumstances or objectives change. The exact service should be clearly defined so clients understand what they receive, when contact will occur and what their ongoing fee pays for.
Are annual financial advice reviews being removed?
The FCA has proposed replacing the fixed annual suitability review requirement for relevant business with a more flexible system of periodic reviews based on client needs, circumstances and the service provided. This does not mean ongoing reviews disappear. The proposal is not yet a final rule, so advice firms should continue following current requirements while monitoring the FCA’s final policy, implementation timetable and any changes made after consultation.
Why is the FCA changing annual review requirements?
The FCA is considering changes because a fixed annual review may not always reflect how different clients actually need ongoing financial advice. A client with stable circumstances may require less frequent formal review, while someone drawing retirement income, selling a business or dealing with complex family wealth may need support sooner. The proposed approach aims to give firms flexibility while maintaining good outcomes, fair value, consumer understanding and appropriate support.
Can advisers still offer annual reviews?
Yes. Advice firms can still offer annual reviews where that frequency is appropriate for the client, the agreed ongoing service and the risks involved. The FCA proposal is about allowing greater flexibility rather than banning annual financial planning or suitability reviews. Firms would still need to explain the service clearly, deliver what was promised and demonstrate why the chosen review approach is suitable for the client.
What should an ongoing advice service include?
An ongoing advice service should clearly state what support the client will receive and how that support will be delivered. Depending on the agreement, it may include periodic suitability reviews, investment monitoring, financial planning updates, adviser access, retirement and tax discussions, cashflow planning and help following significant life changes. The frequency and scope should reflect the client’s needs, and the ongoing charge should be consistent with the service actually delivered.
Can a client be charged for ongoing financial advice if they miss a review?
Whether a client can continue to be charged after missing a review depends on the agreed ongoing service, the firm’s reasonable attempts to deliver it and the circumstances of the client’s non-engagement. Firms should keep clear records of contact attempts and explain any consequences of declining a review. They should also consider whether continuing the service and charge remains fair and appropriate when a client repeatedly does not engage.
How can advice firms prove ongoing advice provides value?
Advice firms can demonstrate value by showing exactly what ongoing service each client receives, why that level of support is suitable and what work has actually been completed. Records should evidence reviews, planning decisions, adviser contact and support between meetings where relevant. Firms can also analyse client feedback, complaints, cancellations, engagement and outcome data to identify whether clients understand the service and whether ongoing charges continue to represent fair value.
Does ongoing financial advice only cover investments?
No. Ongoing financial advice can cover much more than investment performance or portfolio changes. Depending on the agreed service, it may include retirement income, pensions, tax planning, protection, estate planning, cashflow, family wealth and changing business circumstances. A useful ongoing relationship considers how these areas interact and whether changes in the client’s life require the financial plan or previous recommendations to be reviewed.
What should clients ask about an ongoing advice fee?
Clients should ask exactly what their ongoing financial advice fee covers, how frequently they can expect contact, what happens during a review and what support is available between formal meetings. They should also understand who will provide that support, what circumstances trigger additional advice and how the service can be changed or cancelled. Most importantly, the client should be able to see how the charge relates to their needs and the work the firm provides.
What is the first step for an advice firm preparing for FCA changes?
The first step is to review existing client agreements, charging structures, review processes and evidence of service delivery. Advice firms should check that the written proposition accurately reflects what clients receive and that the level of support is appropriate for different client groups. Firms should also be able to explain why each client receives a particular review approach and demonstrate that the ongoing financial advice delivered matches the service promised.
Our sales training for financial services focuses on the moments that can make the difference between an enquiry becoming a client or going elsewhere. That includes prospective clients comparing advisers, questioning fees, struggling to understand their options, saying they need to think about it or going quiet after an initial meeting. Our financial services sales training helps advisers uncover priorities, build trust, make complex information easier to understand and explain the value of their recommendations and ongoing service. The result is a more confident and consistent approach to client conversations, from the first enquiry through to a decision and a lasting relationship.
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