Wealth managers face regulatory push for meaningful client outcomes in ongoing advice

Last year’s regulatory focus on ongoing advice has forced wealth managers to move beyond a compliance checklist and confront a simple question: are clients genuinely receiving value for the fees they pay?

According to a Financial Conduct Authority (FCA) review, around 80% of adviser revenue is derived from charges for ongoing services, covering roughly four million clients. The same regulator found in February 2025 that firms delivered suitability reviews in about 83% of cases, while 15% of clients either declined or did not respond to offers of review and fewer than 2% of cases showed no attempt to deliver the review. Those figures underline both the scale of ongoing charges in the market and the need for firms to be able to evidence the service behind those fees. (FCA)

For many firms, ongoing advice has historically been treated as an administrative exercise: hold the annual meeting, file the paperwork, log a “no change” outcome and justify the charge. But that approach is increasingly at odds with the FCA’s expectations and with the Consumer Duty’s emphasis on consumer understanding. The FCA’s adviser charging rules require firms to set out clearly the details of their charging structures, the service provided and how clients can cancel , transparency that must now be matched by demonstrable service quality. (FCA)

A growing gulf is apparent between recording activity and delivering meaningful outcomes. Clients’ financial lives are rarely static; assets, liabilities and objectives evolve, as do the regulatory and tax landscapes that affect long-term plans. Narrow, product-centred or pension-only reviews risk missing material issues such as protection gaps, borrowing pressures or succession and inheritance implications. Even where these fall outside a firm’s core remit, advisers can add value by guiding clients or referring them to trusted specialists. Joe Norburn, CEO of TCC Group, argues that reviews must be proactive and forward-looking to justify ongoing charges. (Money Marketing; TCC Group)

Firms should also re-examine how they allocate fees against service levels. Industry comparisons and generic benchmarks are useful starting points but insufficient on their own. Fair-value assessment, the FCA suggests, should consider the firm’s actual cost-to-serve, the expertise and effort deployed, and the tangible benefits delivered to the client. Where firms cannot evidence that benefit, they risk not only regulatory scrutiny but also remediation costs: by October 2025 some firms had set aside significant provisions to compensate clients for failing to deliver contracted ongoing services. (FCA; LawPlus)

Regulatory engagement on this topic has been sustained. In February 2024 the FCA requested information from firms on how they deliver ongoing services and assess fair value under the Consumer Duty; subsequent multi-firm reviews and press statements have cemented ongoing advice as an area of supervisory priority. That sustained attention signals that the regulator is prepared to ask hard questions about both process and substance. (FCA)

Operational change is required on several fronts. First, firms must deepen their evidence of client outcomes: notes of “no change” should be replaced by documented, probing conversations that test whether circumstances, objectives or risks have materially shifted. Second, firms should build mechanisms to identify and act on emerging risks , for example, preparing for legislative or tax changes that could alter inheritance or pension outcomes. Third, transparency must be plain and personalised so clients understand exactly what the ongoing charge covers and the benefits they should expect. (Money Marketing; FCA)

For advisers, the commercial incentives are clear. Firms that can demonstrate measurable, client-centred value for ongoing charges are better placed to retain clients, defend their pricing and limit the risk of regulatory intervention or compensation liabilities. Those that continue to rely on box-ticking and generic benchmarking will increasingly find themselves exposed to supervisory challenge and, ultimately, to reputational and financial costs. (FCA; JenCap Partners)

Delivering on the Consumer Duty means shifting the conversation from whether a meeting happened to what changed as a result of that meeting. Firms that adopt a more forensic, outcome-driven approach to ongoing advice , aligning fees with demonstrable benefit, documenting proactive engagement and anticipating future client needs , will be more likely to sustain trusted client relationships and satisfy regulators. Joe Norburn is CEO of TCC Group.