Clearing an annual review backlog: a practical catch-up plan

Almost every firm with a large ongoing book has been there. A busy spell of new business, a staff absence or a market event, and the review calendar slips. A few months later there is a list of clients who are paying for ongoing advice and have not had their review. An annual review backlog is uncomfortable for the adviser, and it is a real regulatory and client outcome risk for the firm.

This guide sets out why backlogs matter, what the FCA has found, and a five-step plan to catch up and stay caught up.

Why an annual review backlog matters

Ongoing charges are tied to ongoing service. Under COBS 6.1A.22R, a firm may only charge ongoing adviser charges for "an ongoing service for the provision of personal recommendations or related services", which must be disclosed, with "a right to cancel the ongoing service… without penalty". Where a firm provides a periodic suitability assessment, COBS 9A.3.9R says it "must review the suitability of the recommendations given at least annually."

The Consumer Duty adds the price and value outcome. A client paying for a service they have not received is the kind of outcome the FCA expects firms to find through their own monitoring. Under PRIN 2A.9.8R, firms must "regularly monitor the outcomes retail customers receive", and a review backlog should show up in that monitoring.

What the FCA found on ongoing advice

On 15 February 2024 the FCA wrote to 22 of the largest advice firms asking for seven years of information and data on ongoing advice. Its findings, published on 24 February 2025, were broadly reassuring for those firms:

• reviews were delivered in about 83% of cases;
• in 15% of cases the client declined or did not respond;
• in fewer than 2% the firm made no attempt to deliver the review.

The FCA also noted that "About 80% of revenue from adviser charges relates to charges for ongoing services from around 4 million clients". Ongoing advice is central to how firms are paid, which is why the regulator watches delivery closely. Two lessons stand out for a firm with a backlog: keep evidence of every attempt to deliver a review, and never be in the group that made no attempt at all. We cover the review in more depth in the FCA's ongoing advice review findings.

Five steps to clear an annual review backlog

The first four steps clear the list. The fifth keeps it clear.

Step 1: size the backlog

You cannot plan what you have not measured. Build a single list of every ongoing client with:

• the date of the last completed review;
• the service level agreed and the ongoing charge being taken;
• the adviser responsible;
• any known change in circumstances since the last review;
• any recorded characteristics of vulnerability.

Sort by how overdue each review is. The number of overdue clients, multiplied by your time per review, tells you how many hours the backlog really represents.

Step 2: triage by risk

Not every overdue review carries the same risk. Work through the list in this order:

Agree the order with whoever is responsible for compliance, and record why you chose it. That record is useful evidence that the firm identified the problem and acted on it.

Step 3: contact, and record every attempt

Some clients will not respond, and some will decline. The FCA's figures suggest that is common. What matters is that the firm made a genuine attempt and kept a record. For each client:

1. offer the review in writing, with a choice of dates and formats;
2. follow up by phone if there is no reply;
3. record each attempt and the client's response;
4. where a client repeatedly declines, consider whether the ongoing service and charge are still right for them, and discuss it with them.

Step 4: speed up the preparation

The meeting is rarely the bottleneck. Preparation is: gathering valuations, separating growth from contributions, checking charges and writing the review document. By our estimate, writing one annual review by hand takes about three hours.

Ways to cut that time:

• Batch the data. Request all valuations for a block of clients at once.
• Standardise the document. One structure, so writers and checkers know where everything goes.
• Use software for the mechanics. Strata reads the platform valuation PDFs the firm already has, separates investment return from money paid in, tracks charges year on year and writes a branded draft, with every figure traced to its report and page. By our estimate, that takes a review from about three hours to about twenty minutes. More detail is in annual reviews written in twenty minutes.

The adviser still adds the judgement and approves the document. The saving comes from the assembly.

Step 5: stop it coming back, and watch CP26/10

Once the backlog is cleared, keep a rolling twelve-month calendar, review capacity monthly against the number of reviews due, and report overdue reviews as a standing item in your Consumer Duty monitoring.

The rules may change. In CP26/10, published on 25 March 2026, the FCA proposes "Replacing the annual suitability review with periodic reviews based on clients' needs". The consultation closed on 22 May 2026 and the policy statement has not been published, so these remain proposals. Until final rules are made, the current requirements apply. Our article on CP26/10 covers what is proposed.

Frequently asked questions

What should we do about clients who will not book a review?

Offer the review in writing, follow up, and record every attempt and response. Where a client repeatedly declines, discuss whether the ongoing service and charge are still right for them.

Does the annual review requirement still apply?

Yes. COBS 9A.3.9R requires a firm providing a periodic suitability assessment to review suitability at least annually. CP26/10 proposes periodic reviews based on clients' needs, but it is a consultation and no final rules have been published.

How can we review more clients without more advisers?

Reduce preparation time: batch valuation requests, standardise the review document and use software for figure extraction and drafting, while the adviser keeps the judgement and the sign-off.

Strata turns platform valuation PDFs into a finished, branded annual review for the adviser to check and approve. Read more about Strata, or book a twenty-minute demo with Adam Booth on Microsoft Teams, run live on a demo firm with nothing for you to prepare.