From 6 April 2026, the new tax year begins. At the same time, a quiet but significant shift in financial services is taking hold—one that the Financial Ombudsman Service (FOS) is already preparing for.
Its expectation is clear: around 11,400 investment and pension complaints will be received in the 2026/27 financial year. Within that number, it anticipates a “significant” proportion linked to a new model known as Targeted Support.
On the surface, this appears to be a routine forecast. In reality, it signals something more fundamental. Not just a rise in complaints—but a change in the type of complaint, and crucially, in how those complaints may be judged.
Because many of them may not succeed.
What is “Targeted Support”?
Targeted Support is a regulatory innovation designed to make financial help more accessible and scalable. It allows firms to offer suggestions, prompts, and guidance to groups of consumers who share similar characteristics.
This might include, for example:
- Suggested pension contribution levels
- Prompts to consolidate or transfer
- Indicative drawdown strategies
- Investment nudges based on age or profile
The critical distinction is that this is not regulated financial advice. It does not involve a full assessment of your personal circumstances, nor does it carry the same legal duty to ensure suitability.
Instead, it sits in a middle ground—more tailored than generic guidance, but less accountable than advice.
For firms, the attraction is obvious. It enables support to be delivered at scale, often digitally, and at significantly lower cost. For consumers, it appears to offer something valuable: relevant, timely help without the barriers traditionally associated with advice.
The difficulty lies in how it is experienced.
The Gap Between Experience and Responsibility
When consumers encounter Targeted Support, it is unlikely to feel like “limited guidance”. It will often appear personalised, relevant, and actionable.
In other words, it will feel like advice.
That perception matters. Because decisions will be made on the basis of that perceived relevance. Money will be invested, withdrawn, or reallocated accordingly.
However, if the outcome later proves unfavourable, the classification becomes decisive.
A complaint may be met with a response along the lines of:
“This was not regulated advice. It was support.”
At that point, the framework shifts. The protections associated with advice—particularly the requirement that recommendations be suitable for the individual—may not apply in the same way. What felt like a personalised recommendation may instead be treated as a generalised suggestion.
This is the structural tension at the heart of the new regime: what feels like advice may not be treated as advice when it matters most.
Why Complaints Are Expected to Rise
The FOS forecast reflects three underlying dynamics.
First, the model is designed for scale. Targeted Support is intended to reach large numbers of consumers, often through automated or semi-automated systems. Even a small percentage of poor outcomes can therefore translate into a substantial number of complaints.
Second, the boundary between guidance and advice becomes harder for consumers to distinguish. When suggestions are framed in ways that appear relevant to personal circumstances, it is entirely reasonable for individuals to interpret them as recommendations.
Third, expectations are likely to outpace the legal framework. Consumers tend to judge outcomes based on what they believed they were receiving, not on how the service is later categorised.
The result is a predictable pattern: decisions made in good faith, followed by dissatisfaction, followed by complaints that may struggle to meet the technical threshold for redress.
Warning Signs to Watch For
As this model becomes more widespread, there are some indicators that you may be engaging with Targeted Support rather than regulated advice.
These include:
- Suggestions framed around people “like you” rather than your specific circumstances
- Pre-filled or default options presented as the “next step”
- Prompts to take action without a detailed assessment of your wider situation
- Language that encourages movement—investing, switching, withdrawing—without explicit confirmation of suitability
None of these are inherently problematic. However, they do signal that the responsibility for the decision may ultimately rest with you.
Practical Steps to Protect Yourself
In this environment, a small number of disciplined habits can make a significant difference.
Before acting on any financial prompt or suggestion, it is worth asking a simple but important question: “Is this advice, or is this guidance?”
If it is not advice, you should proceed on the basis that there may be no formal suitability assessment underpinning the suggestion.
It is also prudent to slow the process down. Many of these systems are designed to facilitate quick decisions. Taking time to reflect, seek a second view, or sense-check the implications can materially reduce risk.
Finally, keep a record. If you are shown a recommendation or prompted to act, capture the wording, the context, and your understanding at the time. This creates a contemporaneous record that can be invaluable if questions arise later.
If a Complaint Is Rejected
If you do experience a poor outcome and your complaint is rejected on the basis that the interaction was “support” rather than advice, the focus should shift.
Rather than relying solely on classification, it becomes important to evidence:
- How the interaction was presented
- The extent to which it appeared personalised
- The understanding it created at the time
- The decision you made as a result
- The financial harm that followed
In essence, the question becomes whether the experience created a reasonable expectation of advice, even if it was not formally defined as such.
A System Becoming Easier to Use—But Not Necessarily Safer
There is a broader trend here. Financial services are becoming more accessible, more responsive, and more efficient. Technology and regulation are combining to deliver support at scale.
However, accessibility and safety are not the same thing.
As systems become easier to engage with, the burden of interpretation increasingly shifts to the individual. Understanding what is being offered—and what is not—becomes a critical skill.
Final Thought
The figure of 11,400 complaints is not just a statistic. It is a signal.
It suggests that many people will enter this new system believing they are being guided safely, only to discover later that the protections they assumed were in place may not apply.
The most effective safeguard is not to avoid engaging with financial tools or support altogether. It is to approach them with clarity.
To understand what you are being given.
To question what sits behind it.
And to ensure that the decisions you make are grounded in your own context, not just the system’s suggestion.
Because in this new landscape, the difference between support and advice is not just technical.
It is consequential.
In practical terms, this places a new responsibility on the individual. Where there is any uncertainty, it is no longer sufficient to rely on how something appears or feels. Taking a moment to interrogate what is being presented—whether independently or with the assistance of AI—can provide an important layer of protection. A simple question can bring clarity: is this suitable advice, or is it support? The distinction may seem technical at the outset, but in the event of a poor outcome, it can determine whether a complaint is upheld or set aside.
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