The FCA ongoing advice review: findings and what to check now

Ongoing advice is the financial heart of most advice firms. Clients pay a fee every year, and in return they expect a service, including a regular review of whether their arrangements are still suitable. When the FCA asked whether firms were actually delivering those reviews, it was asking a question every firm should be able to answer about its own book, with records rather than reassurance.

This article sets out what the FCA ongoing advice review found, the rules underneath it, and a practical set of checks you can run on your own service.

What the FCA ongoing advice review looked at

According to the FCA's multi-firm review of ongoing financial advice services, "On 15 February 2024, we wrote to 22 of the largest advice firms asking for information and data". The request covered seven years of data on the ongoing services those firms had promised and delivered.

The scale of what was at stake is clear from the FCA's own figure: "About 80% of revenue from adviser charges relates to charges for ongoing services from around 4 million clients". In other words, ongoing charges make up the large majority of adviser charging revenue across the market.

The headline findings

The FCA published its findings on 24 February 2025, alongside a press release reporting that the vast majority of ongoing suitability reviews had been delivered. The numbers break down as follows.

At first sight that is reassuring. But look at it from the firm's side. In roughly one case in six, a review the client was paying for did not happen, mostly because the client declined or did not reply. That raises practical questions every firm should be able to answer: how many times did you try, how did you record it, and did the fee carry on regardless?

The review covered 22 of the largest firms, and the FCA notes that its population "was not a representative sample". These figures tell you about some of the market's biggest players, not necessarily about your own book. The only way to know your own numbers is to measure them.

The rules behind ongoing advice

Three rules do most of the work here.

Adviser charges

COBS 6.1A.4R requires that a firm must "only be remunerated for the personal recommendation… by adviser charges".

Ongoing adviser charges

COBS 6.1A.22R allows ongoing adviser charges only for "an ongoing service for the provision of personal recommendations or related services". The service must be disclosed, and the client must have "a right to cancel the ongoing service… without penalty".

The annual review

Where a firm provides a periodic suitability assessment, COBS 9A.3.9R says: "A firm providing a periodic suitability assessment must review the suitability of the recommendations given at least annually."

The Consumer Duty adds a further lens. Price and value is one of its four outcomes, and the FCA's Consumer Duty focus areas list "Expectations for wealth and advice firms when assessing fair value" among the priorities for advice and wealth firms. An ongoing fee charged for a service that was not delivered is hard to reconcile with fair value.

The rules may change. In CP26/10, the FCA has proposed "Replacing the annual suitability review with periodic reviews based on clients' needs". That is a consultation proposal, not a final rule, and the current rules continue to apply. We explain the proposals in CP26/10 and periodic suitability reviews.

Why it matters for firms of every size

The FCA's financial advice firms survey 2025 found that "88% of retail clients receive ongoing advice". With around 150 clients per adviser on the FCA's figures, most advisers carry a large book of ongoing reviews every year. That is a lot of reviews to deliver, evidence and write up, and the pressure tends to fall on the writing.

When reviews are squeezed, two things happen. Some slip past their due date. Others go ahead but are thinly recorded, so the file does not clearly show that the service was delivered or that suitability was actually reassessed. Both are risks under the rules above.

Checks to run on your own ongoing service

These checks are a practical starting point, not an exhaustive or official list.

1. Reconcile fees with reviews. For every client paying an ongoing charge in the last twelve months, is there a completed review in the period? List the exceptions.
2. Classify the exceptions. Split them the way the FCA did: declined, did not respond, or no attempt made. The last group needs action first.
3. Test your attempts. For non-responders, how many contacts were made, by what channel, and are they on file?
4. Check the disclosure. Does each client's agreement describe the ongoing service, its cost and the right to cancel without penalty, as COBS 6.1A.22R requires?
5. Look at what was delivered. Does the service delivered match the service described? If the agreement promises an annual meeting and a written review, are both on file?
6. Check the review itself. Does the review record actually reassess suitability, including any change in circumstances, objectives, attitude to risk or capacity for loss?
7. Review the value. For clients who repeatedly decline reviews, is the ongoing service still right for them, or should it be changed or stopped?
8. Feed it upwards. Put the results in your Consumer Duty monitoring and your annual Consumer Duty board report.

Making the review itself easier to deliver

Each review is also a substantial writing job, which is often where the time runs out. By our estimate, a good annual review takes around three hours by hand: pulling figures from platform valuations, separating real growth from money paid in, checking charges and writing it up in language a client will read.

Strata is built for that part of the work. It reads the platform valuation PDFs the firm already receives, separates investment return from contributions, tracks how charges moved year on year, and traces every figure back to the report and page it came from. It returns a branded, editable review document, with adviser-only judgement sections clearly flagged, ready to export to Word or PDF. By our estimate that takes the review from three hours to around twenty minutes.

Strata produces the draft and the figures. The adviser still reassesses suitability, adds the judgement and signs off. Delivering and evidencing the ongoing service remains the firm's responsibility. If you are behind, our guide to clearing an annual review backlog sets out a practical plan.

Frequently asked questions

What did the FCA ongoing advice review find?

Using data from 22 of the largest advice firms, the FCA found reviews were delivered in about 83% of cases. In 15% the client declined or did not respond, and in fewer than 2% the firm made no attempt.

Do the current rules still require an annual review?

Yes, where a firm provides a periodic suitability assessment. COBS 9A.3.9R requires the firm to review suitability at least annually. CP26/10 proposes periodic reviews based on clients' needs, but that remains a proposal until the FCA publishes final rules.

What should we do if a client keeps declining their review?

Record each attempt and the client's response, and consider whether the ongoing service still offers the client fair value. The decision about whether to change or stop the service is one for the firm to make and evidence.

To see how Strata turns platform valuations into a finished review, read about Strata or book a twenty-minute demo with Adam Booth on Microsoft Teams. It runs on a demo firm, so there is nothing to prepare.