A New Era for Financial Guidance
The Financial Conduct Authority (FCA) published Consultation Paper CP25/17, setting out proposals for a new framework called Targeted Support.
This initiative is designed to tackle a persistent problem in the UK: the financial advice gap. While millions of people need help making decisions about pensions and investments, only 9% of adults received regulated financial advice in the past year. For many, full advice is too costly or unnecessary, yet generic information often feels irrelevant.
Targeted Support aims to change that.
What is Targeted Support?
Targeted Support would allow firms to provide “ready-made suggestions” to groups of customers who share similar needs or circumstances. These suggestions would be more specific than generic guidance but would stop short of constituting a personal recommendation under the FCA’s definition of regulated advice.
For example:
- A pension provider could highlight an appropriate contribution level for customers in their late 40s who are behind on retirement savings.
- An investment platform could suggest a diversified, low-risk portfolio for first-time investors with smaller balances.
The goal is to give customers relevant, actionable options that improve outcomes, without the complexity and cost of a full regulated advice process.
How It Works
The FCA’s proposed framework is structured around four steps:
- Identify situations where customers could benefit from additional help (e.g. approaching retirement with low savings).
- Group customers with similar characteristics or financial needs.
- Create suggestions tailored to each group’s circumstances.
- Deliver these suggestions to customers who match the profile.
Unlike regulated advice provided under COBS 9 and COBS 9A of the FCA Handbook, this model would operate under a new section, COBS 9B, which focuses on good outcomes for the group rather than assessing the suitability for each individual customer.
Rules, Protections and Limitations
- Voluntary participation: Firms may choose whether to offer Targeted Support.
- Consumer Duty compliance: All Targeted Support must aim to deliver good consumer outcomes in line with the FCA’s Consumer Duty (PRIN 2A).
- Scope exclusions: High-risk investments and products with marketing restrictions would be excluded.
- Consumer protections: Customers retain the right to refer complaints to the Financial Ombudsman Service (FOS) if they believe they have been misled or suffered detriment.
Why This Matters
For consumers, Targeted Support could deliver more relevant and practical guidance, enabling better-informed decisions and reducing the risk of poor outcomes caused by a lack of advice. Crucially, they would still have access to the FOS for complaints and redress.
For firms, this creates a new engagement channel with under-served customer segments, offering opportunities to build trust and contribute to improved financial well-being, without the full costs and regulatory obligations of the traditional advice model.
Timeline and Next Steps
The FCA’s consultation on the Targeted Support proposals is open until 29 August 2025, and stakeholders are encouraged to respond before the deadline to help shape the final framework.
Following the consultation, the FCA expects to publish the final rules by the end of 2025. In parallel, HM Treasury will introduce legislative changes under the Financial Services and Markets Act 2000 (FSMA) to establish Targeted Support as a new regulated activity, enabling its formal implementation.
How Can Complyport Help?
Complyport has extensive experience supporting financial services firms in meeting FCA requirements while enabling innovation in customer engagement. We can help you prepare for the introduction of Targeted Support through:
- Consumer Duty Gap Analysis: Assess your current processes and identify areas where you need to enhance outcomes in line with PRIN 2A.
- COBS Compliance Review: Review your advice and guidance frameworks to ensure they meet COBS 9, 9A and the proposed COBS 9B requirements.
- Product Governance Support: Help design and document products and services that comply with scope limitations and avoid high-risk exposures.
- Policy and Procedure Development: Draft or update internal policies to reflect Targeted Support rules and integrate them with your wider compliance framework.
- Training and Staff Awareness: Deliver tailored training sessions to ensure your teams understand the distinction between generic guidance, targeted support and regulated advice.
- FCA Engagement Support: Assist in preparing and submitting consultation responses to ensure your views are reflected in the FCA’s final rules.
Book a Meeting with a Subject Matter Expert
Whether you are reviewing your current advice and guidance framework or seeking clarity on how to prepare for COBS 9B and the FCA’s Targeted Support regime, our SMEs are here to help. We provide tailored consultations designed around your firm’s business model, risk appetite and regulatory obligations. Contact us today to arrange a meeting with a specialist who can guide you through every stage of implementation.
Ask ViCA, your Virtual Compliance Assistant. Claim your complimentary 20 queries today! Register here: https://vica.chat
