FCA ongoing advice rules: what firms need to evidence and how AI can help

Ongoing advice is firmly in the FCA spotlight. A mix of supervisory work, Consumer Duty expectations and broader advice reform means firms are facing closer scrutiny, especially on whether services are delivered consistently and whether they can prove it.

For many firms, ongoing advice is central to both client relationships and revenue. The FCA is not challenging the model itself, but it is asking tougher questions about oversight, consistency, value and how quickly firms can retrieve the right evidence when needed.

Ongoing advice is no longer a supporting component of the proposition. For a large proportion of firms, it is the model.

Ongoing advice compliance: moving beyond process to oversight

At the centre of this is a move away from activity-led thinking towards a stronger focus on oversight. Historically, much of the emphasis has been on whether key processes have been completed, particularly reviews.

Now the question is broader: can firms demonstrate that the service they have defined is actually being delivered and continues to meet client needs?

This is where things often become unclear. Services may be well defined at the outset but oversight can become patchy over time. Management information, quality assurance and monitoring do not always join up, especially where firms still rely on manual checks and fragmented records.

How firms can evidence fair value in ongoing advice

This links directly to how firms define their ongoing service. The FCA has been clear that services should be specific, structured and designed for a clear target market. Firms need to evidence this not just through documentation but through an ongoing demonstration that the service is being delivered as intended, remains appropriate and represents fair value.

It is no longer enough to show that a service exists or that a fee is being charged. Firms need to show:

• how the service works in practice
• who it is helping
• whether the records make that clear when challenged.

Suitability reviews and the shift to a more flexible advice model

One of the most visible areas of change is around suitability reviews. Annual reviews have long been the cornerstone of ongoing advice, often acting as the primary mechanism for both delivery and evidence. For many firms, completion of that review has been treated as confirmation that the service requirement has been met.

The FCA’s CP26/10 consultation proposes replacing the mandatory annual suitability review requirement with a more flexible, periodic approach based on client needs and circumstances.

This is not simply a technical change. It signals a broader shift in how ongoing advice is expected to operate. Rather than relying on a fixed annual cycle, firms will be expected to determine when engagement is appropriate based on the client’s situation, the complexity of their arrangements and how their circumstances evolve over time.

If the annual review is no longer the anchor, firms need to look back to service design: when clients are engaged, what triggers contact and how firms measure whether that contact is delivering value.

Disengaged clients: a growing ongoing advice risk

Alongside this, the FCA has continued to highlight the issue of disengaged clients. Not all clients actively use ongoing services even when they are paying for them. That creates a clear risk. For instance, if engagement is low, it becomes more difficult to demonstrate that services are being delivered in a meaningful way and whether they represent fair value.

The point is not that every client must engage all the time. It is that firms should know where disengagement exists and respond appropriately through re-engagement, service changes or, in some cases, reassessing whether the arrangement is still right.

Consumer Duty and the move to outcome-led ongoing advice

Taken together, these developments point to a more outcome-led model of ongoing advice: moving away from evidence that something has been done and towards demonstrating that it has made a difference. This is closely aligned with the Consumer Duty, which emphasises good outcomes rather than completed activity.

For firms, this does not necessarily mean a complete redesign of their operating model. In most cases, the foundations are already there. The challenge is to strengthen how those models are governed, monitored and evidenced, without creating an unsustainable manual burden for compliance and advisory teams.

Why AI is becoming essential for ongoing advice oversight

In practice, that means checking whether services are clearly defined, delivered consistently and backed by management information that reflects reality. It also means making sure review cycles and engagement models are built around client needs, not internal habits.

The thread running through all of this is simple: firms need to be better at showing that their ongoing advice model works. For many, smarter use of technology, automation and AI can take much of the manual effort out of oversight. For some organisations this may be a natural extension of what is already in place; for others, it will require a more fundamental rethink of how ongoing services are structured, monitored and overseen.

Ongoing advice is no longer just about keeping in touch or completing an annual process. It is about being able to show, clearly and consistently, that the service is still delivering value.

Recordsure helps firms monitor ongoing advice activity, spot missing evidence, flag delivery gaps and create a clearer audit trail across reviews and client interactions. The result is less time spent hunting through records and more confidence that oversight stands up when it matters.