FCA scrutiny is reshaping ongoing advice

The FCA has been setting out its expectations for consumer investments and ongoing advice with growing openness. Through its new Regulatory Priorities approach, the regulator is asking boards and senior leaders to review what applies, take action and evidence the outcomes. For wealth and advice firms, that increasingly brings ongoing advice into focus.

Ongoing advice used to be defended through processes such as annual reviews, standard service tiers and a “we’ve always done it this way” rhythm. Under the Consumer Duty, that logic is weakening. The FCA is now testing whether firms can demonstrate that ongoing services remain appropriate, valuable and responsive over time. In other words, not whether they have a framework but whether they can prove it works in practice.

The regulator is explicit that building a healthier investment culture may involve consumers taking risk, and sometimes experiencing loss, without that automatically being a regulatory failure. That places more weight on firms being able to show clients understood risk, were supported appropriately and received a service that evolved with their needs.

The FCA’s consultation on simplifying pensions and investment advice rules signals a broader move away from rigid, one-size-fits-all processes and towards proportionate judgement backed by stronger accountability. Proposals such as moving from annual to periodic suitability reviews based on client needs and clarifying expectations for disengaged clients are directly relevant to ongoing advice models.

What the FCA is testing in ongoing advice

For compliance, technology and risk leaders, the supervisory question set is becoming consistent:

• Trigger-based engagement, not automatic cycles: can firms show how they decide when engagement is genuinely required, and what data or events prompt action?
• Changing circumstances between reviews: how do firms identify vulnerability, life events, changes in objectives, risk tolerance or capacity for loss before the next formal touchpoint?
• Fair value over time: where client engagement is light, how do firms evidence that ongoing fees remain justified and aligned to benefits actually received?
• Insight to action: when monitoring identifies friction, poor outcomes or emerging risks, can firms demonstrate that the decisions taken had control environment behind them?

The evidencing phase is where many firms feel the strain. Good governance is not new, but supervision is increasingly anchored in demonstrable control, measurable outcomes and retrievable evidence at a scale that manual quality assurance and periodic sampling struggle to meet.

Where Recordsure fits: QA and compliance evidence, at scale

Recordsure is built for this moment. It helps wealth and advice firms turn day-to-day interactions into structured, searchable compliance evidence without relying on hindsight or manual file reconstruction.

Recordsure solutions include:

• Capture and Meeting Notes summaries: create a reliable record of adviser-client interactions, in person or online, and turn conversations into consistent meeting summaries and follow-up actions, creating the evidence base ongoing advice now depends on.
• Recordsure technology: apply advanced speech and document analytics to monitor advice quality and Consumer Duty risks at scale, highlighting risk indicators and suitability concerns earlier and more consistently across the business.

Leading advice firms, like Attivo, are already implementing Recordsure’s AI technology to improve ongoing advice compliance while reducing file review costs, as described in this related article.