What the regulator’s findings mean for people who wanted financial planning but were offered an ongoing investment relationship
By Steve Conley | Academy of Life Planning
You had a question.
Could you afford to retire? Could you help your children financially? Could you buy your dream home? Could you change career without putting your future at risk?
You went looking for financial planning.
But somewhere along the way, the conversation turned to your pensions and investments. How much did you have? Where was it held? Could it be moved into a portfolio the adviser would look after for an ongoing charge?
Perhaps the adviser helped answer your question. Perhaps you found the ongoing relationship valuable.
Or perhaps, years later, you are still paying a percentage of your assets and wondering whether the service you bought is the one you originally needed.
If that sounds familiar, you are not alone.
Over the past 15 years, almost every prospect who subsequently became a personal client of mine had experienced some version of this conversation. Some had accepted an ongoing service and later questioned its value. Others had wanted help with a particular decision but struggled to find someone willing to provide it without taking responsibility for their investments.
The Financial Conduct Authority recognised a version of this problem back in 2020.
Six years later, the central question remains: how many people are paying for an ongoing service because it meets their needs, and how many are paying because it became the default?
What the FCA found in 2020
In its evaluation of the Retail Distribution Review and Financial Advice Market Review, the FCA examined both consumer demand and the way advice firms operated.
It found that consumers facing decisions they considered more complex indicated that they wanted one-off support for a specific decision. They did not generally believe they needed regular ongoing support, although the FCA noted an exception: help with managing an investment portfolio.
The regulator also found that, among firms offering both one-off and ongoing advice, more than 90% of new customers were placed into ongoing advice arrangements.
The FCA was concerned that ongoing advice might be a default option, rather than something always justified by the customer’s circumstances. Its concern was that:
“some customers might be paying for a service they do not need.” www.fca.org.uk
Those are not my words. They are the regulator’s.
The consumer research and the firm data do not prove that every person who wanted one-off help ended up buying an ongoing service. They do, however, expose a question about whether the services people want are the services the market makes easiest to obtain.
The FCA also found that many consumers who had received advice did not clearly understand how much they were paying. Some judged value by looking at investment performance, even though performance and the charge for advice are different things.
That matters. A rising portfolio may make a client feel reassured, but it does not, on its own, explain what the adviser did, what the service cost, or whether another arrangement would have met the client’s needs.
Six years on, ongoing advice remains the dominant model
The FCA’s 2025 financial advice firms survey, published in April 2026, says around 90% of active retail clients are in ongoing advice arrangements.
Its 2026 consultation says about 80% of revenue from adviser charges comes from ongoing services, involving around 3.7 million clients. www.fca.org.uk
These figures do not tell us that the services are unnecessary. They do tell us that recurring advice charges remain central to the industry’s business model.
And that raises a question about incentives.
A firm that earns a continuing percentage of assets has a commercial reason to retain those assets within an ongoing relationship. That does not mean its advisers are acting dishonestly, or that clients cannot benefit. It does mean the customer should be able to see clearly what is being provided and consider whether another arrangement would better suit them.
A service should continue because it remains useful to the person—not simply because the charging arrangement continues.
The review that counted delivery
In 2024, the FCA asked 22 large advice firms for information about their ongoing services. It published its findings in February 2025.
Based on the data firms supplied, where suitability reviews had been promised:
- Around 83% were delivered.
- In a further 15%, the client had declined or had not engaged with the firm’s request.
- In fewer than 2%, the firm reported making no attempt to provide the review.
The FCA said it did not then regard non-delivery as a systemic issue. It also acknowledged that the sample was not representative of the whole market and that results differed between firms. FCA
The review included examples of good and poor practice. But the headline numbers answer a particular question: was a promised review delivered, declined or not pursued?
They do not tell us, across the market:
- Whether the client needed the ongoing service in the first place.
- Whether the review addressed the client’s most important financial questions.
- Whether the conclusions were suitable and useful.
- Whether the overall service represented fair value for the price paid.
- Whether a different combination of investment management and occasional planning support would have suited the client better.
A meeting can take place without resolving the question that brought someone through the door.
Counting reviews is not the same as measuring outcomes.
What the FCA has said about people building their pensions
I have been looking for the FCA’s position on people in the accumulation phase: those still building their savings and pensions for retirement.
The relevant statement is in the FCA’s March 2026 consultation on pensions and investment advice rules.
The FCA says that for some clients—particularly people with simpler, low-risk investments or younger consumers accumulating for retirement—less frequent suitability reviews might better fit their needs. It proposes replacing the prescribed annual review requirement, where it applies, with periodic reviews based on the client’s circumstances. The consultation suggests that a service with less frequent reviews could be priced accordingly. fca.org.uk
That is not the same as saying that everyone building a pension needs no ongoing advice. Nor are the proposed rules final: the consultation closed in May 2026, and the FCA’s consultation page says it will publish feedback and a policy statement after considering responses. www.fca.org.uk
But the FCA’s observation is significant. If someone’s circumstances are stable and their investments are relatively simple, why should an annual review be assumed to be necessary? And if the work becomes less frequent, how will the continuing charge change?
Consumers deserve an answer in pounds, not just percentages.
The individual reviews and what has been made public
The FCA can use a Section 166 skilled person review to obtain an independent assessment of a firm’s activities. The existence of such a review is not, by itself, proof of wrongdoing. FCA
There has been public information about two major firms’ work on historic ongoing services.
Quilter says a skilled person was appointed following discussion with the FCA to assess the delivery of ongoing advice services within its advice network. The final report was submitted to the FCA in the first half of 2025, and Quilter developed a customer remediation exercise. At 30 June 2026, it reported a remaining provision of £30 million for estimated refunds, interest and administration, and said £1 million had been paid to customers during the first half of that year. Investegate
St James’s Place has also undertaken a substantial historic servicing review. It initially announced a provision of £426 million. Its half-year results showed a remaining ongoing service evidence provision of £110 million at 30 June 2026, following payments, costs and releases. The remaining provision includes estimated refunds, interest and administration; it is not simply the amount customers will receive. www.professionaladviser.com
These exercises matter to customers who paid for a service that was not delivered or cannot be adequately evidenced. Claims management companies have also been active in this area.
But there is a further question that a delivery review may not resolve:
If the review happened, was the ongoing service itself what the customer needed—and was the outcome worth the cost?
I have not found a published FCA market-wide assessment that answers that question comprehensively, or a published report setting out the detailed results of its follow-up with the small number of firms it asked about remedial action. That does not mean the FCA has done no work or holds no further information. It means consumers do not yet have a clear public answer to the wider question of need, quality and value. fca.org.uk
The cost of waiting
In 2020, the FCA warned that some customers might be paying for ongoing advice they did not need.
In 2022 alone, more than £5 billion was paid to advisers for ongoing services, according to FCA data reported by FT Adviser. www.ftadviser.com
That figure does not tell us how much was paid unnecessarily. Many people will have received a service they wanted and valued.
But it does show the scale of the question.
If even a proportion of those customers were paying for a service that did not reflect their needs, the financial consequences could be substantial. And while the FCA continues to consider the rules, charges continue to be collected.
The latest FCA figures show that firms reported £6.5 billion in total retail investment intermediation revenue in 2025. That figure includes more than ongoing advice charges, so we should not treat it as the recurring-fee total. Separately, the FCA says around 80% of adviser-charge revenue comes from ongoing services. www.fca.org.uk
For an individual customer, the cost of waiting is easier to see.
A person paying an ongoing adviser charge of 0.8% on a £500,000 portfolio pays £4,000 a year, assuming the portfolio value remains unchanged. Another year spent uncertain about whether the service is right for them could mean another £4,000 in charges.
That does not make the charge unfair by itself. The question is what the person receives for it, whether it meets their needs and whether an alternative would offer better value.
Six years after the FCA identified the concern, consumers should not have to wait for a market-wide answer before asking what their own ongoing service is doing for them.
The regulator faces a question of priorities
The FCA has a role in protecting consumers and supporting a functioning financial services market. It also has a growth and competitiveness objective.
There can be a tension between those aims. A finding that large numbers of customers are paying for services they do not need could have consequences for firms whose revenues depend on ongoing charges.
That does not establish that the FCA has withheld findings to protect industry growth. I have seen no evidence for that claim.
But it is a reason to ask for greater transparency.
The public should be able to see how the regulator is assessing whether ongoing services are necessary, appropriate and fairly priced—not just whether a review was offered or recorded.
A thriving advice market should be one in which people can find the support they need, at a price they understand, for as long as they need it.
Financial planning and investment management are different services
Investment management may involve selecting investments, monitoring a portfolio, rebalancing, reporting and carrying out transactions. Depending on the arrangement, it may be provided continuously by a discretionary manager, through a managed portfolio service, or through funds that themselves manage investments.
Financial planning starts with a different set of questions:
- What matters to you?
- What are you trying to achieve?
- What resources do you have?
- What choices are available?
- What are the consequences of each choice?
- What needs to happen next?
The two services can complement each other. But they are not interchangeable.
You may need your investments managed continuously while only needing a detailed planning conversation at particular points in your life. You may value an ongoing planning relationship as well. Or you may be comfortable managing much of your own financial life and seeking expertise when something changes.
You should be able to understand the choices.
It is also worth asking whether you are paying separately for several layers of investment oversight: an adviser, a portfolio manager, a platform and the underlying funds. Each layer may have a role, but each should be visible and understood.
And if you are paying for active investment management, it is reasonable to ask what it has added after costs, compared with an appropriate alternative. That comparison needs to account for risk, objectives and the period measured; outperformance is not guaranteed, and a single year’s result rarely tells the whole story.
What could episodic support cost?
Let us take a simple example.
Suppose you have a £500,000 investment portfolio and pay an ongoing adviser charge of 0.8% a year.
That is £4,000 a year.
If the portfolio value and percentage stayed unchanged for ten years, the adviser charge would total £40,000.
Now suppose you instead needed three hours of planning support each year at £200 an hour.
That would be £600 a year, or £6,000 over ten years at an unchanged price.
| Illustrative cost | Annual | Over ten years |
|---|---|---|
| Ongoing adviser charge: 0.8% of £500,000 | £4,000 | £40,000 |
| Episodic planning support: three hours at £200 | £600 | £6,000 |
| Difference | £3,400 | £34,000 |
The difference in this example is £34,000.
These are not like-for-like packages. The ongoing service may include investment-related work, access and other benefits that the episodic planning service does not. If you need investment management separately, its cost must be added to the comparison.
The calculation also assumes the portfolio value, percentage and hourly price remain unchanged. In real life they can change, as can your need for support. The example does not include fund or platform costs, tax, inflation or the potential effect of fees on investment growth.
The purpose is not to declare one model cheaper for everyone. It is to make the question visible:
What am I receiving for the difference—and do I need it?
What you can do now
You do not have to wait for the FCA to publish another report before asking questions about your own arrangements.
1. Find out what you agreed to
Look for your client agreement, suitability reports, review letters and fee statements.
Ask your adviser to explain:
- What ongoing services you are paying for.
- How much you pay in pounds each year.
- What has been done for you over the past 12 months.
- What planning outcomes the work has produced.
- What you pay separately for funds, platforms and investment management.
- How you can change or cancel the ongoing service, and what the consequences would be.
The FCA says firms should explain the ongoing service, its charges and how clients can cancel it. FCA
2. Prepare for a better conversation
I created Ask My Adviser™ to help people examine their documents and prepare an agenda for a fair, informed conversation with their adviser.
You might ask:
“What financial planning work have you done for me beyond reviewing my investments?”
“Which of the questions I originally came to you with have we resolved?”
“Could I pay for help with a specific decision when I need it?”
“If I stopped the ongoing advice service, what would happen to my investments, charges and access to support?”
A good adviser should welcome a capable customer who wants to understand the service.
3. Compare your alternatives
Use the Charges Comparison Calculator linked in my recent subscriber email to explore the difference between ongoing asset-based charges and the cost of support when you need it.
Make sure you compare the services as well as the prices. If one option includes investment management and another does not, identify what that missing service would cost—or whether you want it at all.
Do not cancel an arrangement or move investments simply because one headline number is lower. First establish what would change, what support you would lose, what charges would remain and whether there are any product restrictions or consequences.
4. Raise a concern if you need to
If you believe you have paid for a service you did not receive, you can complain directly to the firm. The FCA says consumers do not need to use a claims management company to do this.
If you are unhappy with the firm’s response, or do not receive a response within eight weeks, the Financial Ombudsman Service may be able to help. FCA
There is another way to receive support
At Total Wealth Planner, our starting point is the person and the problem.
We help you understand your circumstances, explore alternatives and decide what to do next. We do not sell financial products or take responsibility for managing your investment portfolio.
That means our planning support is different from regulated investment advice and investment management. If you need a personal recommendation about an investment or another specialist service, you may need an appropriately authorised professional as well.
But you should not have to hand over your portfolio just to begin a conversation about your life.
Bring me the problem, not the portfolio.
If you would like to discuss what you discover from Ask My Adviser or your charges comparison, you can book a 50-minute Zoom meeting for £50.
We can look at your questions, your options and the support you may need next.
The FCA recognised six years ago that some customers might be paying for a service they do not need. Until there is a clearer public answer about how widespread that problem is, there is one question every customer can ask for themselves:
Am I paying for the service I need—or simply the service I was offered?
Life before money. Agency before advice.
