The Financial Conduct Authority (FCA) is expected to publish a Policy Statement and final rules in December 2025 in response to feedback from both Consultation Papers CP25/26 and CP25/17. These proposed changes to the FCA Handbook are designed to introduce a new regulatory framework for “targeted support”, a form of personalised assistance intended to help consumers make better financial decisions.
Targeted support is intended to sit between regulated financial advice and generic financial guidance, enabling firms to support consumers with similar financial needs without crossing into the provision of full advice, a boundary clearly defined in the FCA Handbook under PERG 8.25 and COBS 9.1.
Purpose of CP25/26
While CP25/17 established the broad framework for targeted support, CP25/26 focuses on the consequential Handbook changes needed to ensure the new regime integrates smoothly with existing FCA requirements.
In particular, the consultation proposes:
- Ensuring effective interaction between the targeted support framework and existing rules such as those relating to pension freedoms and investment communications.
- Refining earlier proposals from CP25/17, particularly around commission structures, charging models and disclosures to enhance transparency and consumer understanding.
- Aligning the targeted support activity with the wider regulatory framework, including reporting, governance, complaints and remuneration rules, including compatibility with Senior Management Arrangements, Systems and Controls sourcebook (SYSC), the Dispute Resolution: Complaints sourcebook (DISP) and the Conduct of Business Sourcebook (COBS).
Who Will Be Affected
The proposed rules will be relevant to a wide range of market participants, including:
- Firms subject to the COBS 19 provisions;
- Pension and investment firms, including fund and wealth managers, platforms and Self-Invested Personal Pension (SIPP) operators;
- Pension trustees and trust-based pension schemes;
- Banks, building societies and friendly or mutual societies; and
- Financial advice firms, professional services providers, trade bodies and consultancy firms.
What Firms Should Consider
Firms preparing to offer targeted support, or whose products or services may be distributed under this model, should begin planning now. Key considerations include:
- Authorisation Requirements: Firms will need a new regulatory permission to provide targeted support. The FCA’s authorisation gateway is expected to open in March 2026.
- Governance and Accountability: Under SM&CR, Senior Managers should ensure targeted support features within responsibility maps, with suitable oversight, training and controls.
- Systems and Controls: Firms must review their processes to ensure targeted support is delivered fairly, consistently and within Consumer Duty expectations.
- Disclosure and Charging: Firms must provide clear, upfront communications to clients on how targeted support is funded, whether via direct charges or cross-subsidisation.
- Data and Reporting: The FCA will introduce specific reporting obligations to track targeted support activity distinctly from advised sales.
- Complaints and Redress: The FCA’s DISP rules will be updated to include targeted support, so firms should adapt complaints-handling procedures accordingly.
- Pensions Communications: Pension firms will need to integrate targeted support information into annual statements and ensure it aligns with pension dashboards.
How Complyport Can Help
Complyport can help your firm manage the compliance challenges arising from these regulatory developments by providing:
- Regulatory Reporting Support: Guidance on interpreting and implementing the FCA’s new data and reporting obligations for targeted support.
- Operational Process Mapping: Support in reviewing and aligning internal processes to ensure accurate recording, segmentation and audit trails for targeted support transactions.
- Ongoing Compliance Support: Continuous assistance to ensure your firm’s frameworks remain aligned with evolving FCA requirements.
- Compliance Monitoring and Gap Analysis: Conducting gap analyses and building bespoke monitoring programmes to assess ongoing compliance with the FCA’s reporting and oversight expectations.
- Training and Workshops: Bespoke sessions to embed best practices, strengthen oversight, and foster a strong culture of consumer-focused compliance.
Contact Us
To understand how these developments may impact your business and discuss your compliance needs, contact Complyport today to speak with one of our Subject Matter Experts.
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