When “Ongoing Advice” Stops Being Observable

There’s a quiet shift happening in financial planning.

And it goes to the heart of trust.


For years, the industry has operated on a familiar model:

  • A client pays ~1% AUM
  • In return, they receive an “ongoing service”
  • Typically anchored around an annual review

That annual review did more than provide advice.

It provided evidence.

Something tangible the client could point to and say:

“That’s what I’m paying for.”


Now that anchor is being removed

The move away from mandatory annual reviews is being welcomed as:

  • Flexibility
  • Efficiency
  • A step toward closing the advice gap

And to be clear — flexibility is a good thing.

Not every client needs an annual review.

Not every life needs to be revisited on a fixed schedule.

The primary FCA source behind this story is their consultation paper CP26/10, published on 25 March 2026.

Here’s the direct source:


But here’s the real question

What replaces the evidence of value?

Because if you remove the requirement to deliver something observable…

What ensures the client still receives something meaningful?


The uncomfortable reality

Even before this change, there was already tension in the system:

  • Many clients paying ongoing fees
  • For relatively light-touch engagement
  • Often concentrated into a single annual meeting

Now, that minimum visible touchpoint disappears.

Which means we risk moving from:

Observable service → Interpreted service


And this is where technology changes everything

We are no longer in a world where reviews are scarce or expensive to produce.

Today:

  • Portfolio analysis
  • Cashflow modelling
  • Scenario testing

Can all be done with AI at near-zero marginal cost

That’s not theory.

That’s already happening.


So the comparison becomes unavoidable

Clients are beginning to realise:

  • The technical components of a review are no longer costly
  • The thinking and judgement are where real value lies

Which raises a simple, fair question:

“If the underlying work is now near-zero cost… what exactly am I paying for?”


This is not an attack on advisers

Good advisers do far more than run numbers.

They provide:

  • Context
  • Judgement
  • Behavioural coaching
  • Clarity during uncertainty

That work is valuable.

Often more valuable than ever.


But the pricing model hasn’t caught up

The challenge is this:

  • Fees are often still tied to assets
  • While value increasingly comes from thinking

And now, with fewer required touchpoints:

  • Service becomes harder to observe
  • Value becomes harder to evidence
  • Fees remain unchanged

The real risk: invisible downgrade

This is where consumer harm can quietly emerge.

  • Reviews happen less frequently
  • Engagement reduces
  • The service becomes more passive

But:

  • The fee continues
  • The client assumes everything is “ongoing”

The service changes… but the pricing signal doesn’t.


This is the moment for clarity, not confusion

Flexibility in review frequency is sensible.

But flexibility must be matched with:

  • Transparency
  • Client understanding
  • Clear linkage between fee and value

Otherwise, we normalise a model where:

Payment continues… but value becomes harder to see.


A better direction

The future of financial planning isn’t about:

  • Annual reviews vs no reviews

It’s about:

Delivering value when it matters most

At moments of:

  • Complexity
  • Stress
  • Change

With everything else supported by:

  • Tools
  • Education
  • AI-enabled self-direction

A simple principle

If the service becomes lighter…

The pricing and proposition should reflect that.

Clearly. Explicitly. Honestly.


Final thought

This shift doesn’t have to weaken trust.

But if handled poorly, it could.

Because in any profession:

Trust is not built on what is promised.
It’s built on what can be clearly seen, understood, and experienced.


Curious how others see this.

Leave a comment