CP26/10 explained: periodic reviews and a single attitude to risk

Few consultation papers matter as much to the day-to-day running of an advice firm as CP26/10. It proposes changes to two things almost every firm does all year round: the annual suitability review and the assessment of attitude to risk. If the proposals go ahead as drafted, they could change how firms schedule reviews, how they assess risk and how they describe their ongoing service.

The important word is "if". CP26/10 is a consultation. The FCA has not yet published a policy statement, so the current rules still apply in full. This guide explains what is proposed, what is not changing yet, and what a sensible firm can do now.

What CP26/10 is

CP26/10 Simplifying the pensions and investment advice rules was published on 25 March 2026. The consultation closed on 22 May 2026. At the time of writing, the policy statement with final rules has not been published, and we do not know when it will be or how far the final rules will match the proposals.

Everything below describes proposals. None of it is in force.

The main CP26/10 proposals

The FCA's consultation page lists the main proposals. Quoting the FCA where its wording is given, they include:

• "Replacing the annual suitability review with periodic reviews based on clients' needs";
• merging COBS 9 and COBS 9A into a single set of suitability rules;
• "Introducing a single 'attitude to risk' concept… firms do not need to use complex tools or detailed questionnaires to assess it";
• "Retiring FG 17/8";
• a proportionate approach to assessing a client's ability to bear losses.

Periodic reviews based on clients' needs

Today, where a firm provides a periodic suitability assessment, COBS 9A.3.9R requires it to "review the suitability of the recommendations given at least annually." The proposal would replace the fixed annual review with periodic reviews based on what each client needs.

In practice, that could mean some clients reviewed more often than once a year and others less often, with the firm deciding and justifying the frequency. It would put more weight on the firm's reasoning for each client's review cycle, and on recording that reasoning.

A single attitude to risk concept

The proposal for a single attitude to risk concept, which firms would not need complex tools or detailed questionnaires to assess, would be a notable shift for firms that rely heavily on psychometric questionnaires. It sits alongside the proposed proportionate approach to ability to bear losses. We look at how attitude to risk and capacity for loss fit together today in capacity for loss vs attitude to risk.

One set of suitability rules

Merging COBS 9 and COBS 9A would bring the suitability requirements into one place. Firms that currently work across both chapters would, if this goes ahead, have a single set of rules to map their processes and templates against.

What is not changing yet

Until final rules are published and come into force, firms should keep working to the current requirements. In particular:

• Annual reviews. Where COBS 9A.3.9R applies, suitability must still be reviewed at least annually.
• Ongoing charges. COBS 6.1A.22R still allows ongoing adviser charges only for "an ongoing service for the provision of personal recommendations or related services", disclosed, with "a right to cancel the ongoing service… without penalty".
• Know your client. COBS 9A.2.1R still requires firms to obtain information including the client's "financial situation including his ability to bear losses" and "investment objectives including his risk tolerance".
• The Consumer Duty. The Duty's outcomes, including price and value, continue to apply to the ongoing service whatever its frequency.

The FCA's own data shows why the review question matters. Its ongoing advice review of 22 large firms found reviews delivered in about 83% of cases, with 15% where the client declined or did not respond and fewer than 2% where the firm made no attempt. We cover those findings in the FCA ongoing advice review.

What advice firms can do now

Waiting for the policy statement does not mean doing nothing. Several steps make sense whatever the final rules say, and none of them requires you to change your client agreements before the rules are settled.

1. Know your review book. List every client paying an ongoing charge, their last review date and the service their agreement describes. You will need this under the current rules and under any new ones.
2. Think about need. Consider which clients genuinely need more attention, for example those drawing an income, approaching retirement or with characteristics of vulnerability, and which have simpler, stable arrangements. Do not change anyone's service yet, but understand your book.
3. Record your reasoning. If the proposals go ahead, firms may need to explain why a client is reviewed at a given frequency. Start building the habit of recording why the service suits the client.
4. Review your risk process. Look at how much your attitude to risk assessment relies on a questionnaire score, and how clearly your records show the conversation behind it.
5. Keep reviews on time. The current annual requirement stands. A backlog now is a problem now, whatever happens later. Our guide to clearing an annual review backlog may help.
6. Watch for the policy statement. When it is published, read the final rules and the implementation date before changing agreements, disclosures or templates.

Where Strata fits, under either regime

Whether reviews stay annual or become periodic based on need, each one still has to be written. By our estimate, a good review takes around three hours by hand, most of it spent pulling figures from platform valuations, separating growth from contributions, checking charges and writing a narrative the client will read.

Strata reads the platform valuation PDFs your firm already receives, compares two or more periods across the whole span since the last review, separates genuine investment return from money paid in and tracks how charges moved. Every figure is traced back to the report and page it came from. The review comes back as a finished, branded and editable document, with adviser-only judgement sections flagged, ready for Word or PDF. By our estimate that takes a review from three hours to around twenty minutes.

Because Strata compares whatever periods you give it, it suits a fixed annual cycle and a needs-based one equally well. The judgement about suitability, and about how often each client should be reviewed, stays with the adviser and the firm.

Frequently asked questions

Has CP26/10 removed the annual suitability review?

No. CP26/10 proposes replacing the annual suitability review with periodic reviews based on clients' needs, but it is a consultation. The consultation closed on 22 May 2026 and final rules have not been published, so COBS 9A.3.9R continues to apply.

Will firms still need risk questionnaires under CP26/10?

The proposal describes a single attitude to risk concept where "firms do not need to use complex tools or detailed questionnaires to assess it". Until final rules are published, firms should continue to meet the current requirements and the existing guidance.

Should we change our client agreements now?

We would wait for the policy statement and its implementation date before changing agreements or disclosures. In the meantime, preparing your data and recording your reasoning are useful under any outcome.

To see how Strata handles reviews across any number of periods, read about Strata or book a twenty-minute demo with Adam Booth on Microsoft Teams, run live on a demo firm with nothing to prepare.