Recording client meetings: the rules for financial advisers

If your firm records and transcribes client meetings, perhaps through a meeting service such as Fireflies, a fair question follows: are you required to record client meetings, and if you do, what rules apply to the recordings? Answers in the industry vary, and some of what is said refers to rules that moved years ago.

This guide sets out what the FCA Handbook says about recording client meetings for financial advisers, what it does not say, and good practice for firms that choose to record.

Where the recording rules live now

Older procedures and guidance sometimes refer to COBS 11.8 for recording requirements. That section was "last in force on 02/01/2018". The rules moved to SYSC 10A, which is where firms should now look.

If your compliance manual, procedures or training still cite COBS 11.8, they are out of date and worth correcting. An outdated reference is an easy fix.

What SYSC 10A requires, and what it does not

The SYSC 10A rules concern conversations and communications relating to orders and transactions. Three points matter most for advice firms.

Face-to-face meetings can be recorded in notes

SYSC 10A.1.13R says: "the content of relevant face-to-face conversations with a client may be recorded by using written minutes or notes."

In other words, where a face-to-face conversation is within the rules, written minutes or notes are an accepted way to record it. The rules do not require face-to-face meetings to be audio-recorded.

Retention

Records kept under SYSC 10A must be retained for "five years and, where requested by the FCA, for a period of up to seven years".

Scope is a question to check

Because the rules are framed around orders and transactions, whether a particular advice conversation falls within them depends on what happened in it. We do not offer a view on that here. Check the rules against your own business, and take compliance advice if you are unsure which of your conversations are in scope.

Other rules that touch meeting records

Even where SYSC 10A does not apply, firms still need records of their advice. SYSC 9.1.1R says: "A firm (other than a common platform firm) must arrange for orderly records to be kept of its business and internal organisation… sufficient to enable the FCA to monitor the firm's compliance".

Suitability records have their own retention periods under COBS 9.5: "indefinitely" for pension transfers, conversions and opt-outs, "five years" for life policies and pensions, and "three years" in other cases. A meeting note or transcript that forms part of the evidence for a recommendation is part of that picture.

There is also data protection to consider. A recording or transcript of a client meeting will contain personal data, and processing it with AI brings in further obligations. The ICO's (now the Information Commission's) guidance on AI and data protection, currently under review following the Data (Use and Access) Act, says: "In the vast majority of cases, the use of AI will involve a type of processing likely to result in a high risk… and will therefore trigger the legal requirement for you to undertake a DPIA." It also says "it is your responsibility to decide which lawful basis applies".

Why firms record meetings anyway

If notes are enough for face-to-face conversations within the rules, why record at all? The reasons are practical:

• A complete record. Notes summarise. A transcript keeps the client's exact words, which can matter when understanding, risk or vulnerability is later questioned.
• Better documents. A transcript is a strong starting point for the discovery notes, scope of work and attitude to risk documents that follow a meeting.
• Coaching and competence. Supervisors can review real meetings rather than relying on the occasional sat-in session.
• Consumer Duty evidence. Recordings can show how information was explained and what support was offered, which links to the consumer understanding and consumer support outcomes.

Good practice for recording client meetings

None of the following is a quoted regulatory requirement. It is the practice we would expect a careful firm to adopt.

1. Tell clients, clearly and in advance, that you record meetings, why, how long recordings are kept and who can access them.
2. Complete a DPIA for your recording and transcription process, and for any AI processing of transcripts, in line with the ICO guidance above.
3. Decide your lawful basis and document it.
4. Set a retention policy that meets the longest period that applies to the record, and delete in line with it.
5. Control access. Restrict who can listen to or read recordings, and keep a record of who does.
6. Still write a note. A short adviser summary of the key points and decisions makes the record usable without replaying an hour of audio.
7. Use the recordings. A transcript that is never read gives the firm little benefit for the risk it carries.
8. Keep procedures current, citing SYSC 10A rather than COBS 11.8.

Getting value from recorded meetings

The last point on that list is the easiest to neglect. Recordings are made for compliance, the transcript lands in a folder, and nobody opens it again. The record exists, but the firm learns nothing from it.

Asclto connects to Fireflies, where the firm's meetings are already recorded, and turns each one into a scored internal report. It measures talk share between adviser and client, open versus closed questions, the questions the client asked and the longest adviser monologue. It reads tone of voice from the audio, scores nine dimensions, gives a meeting score and an adviser score out of ten, picks out key moments with the exact words and writes a coaching plan. An FCA checklist shows what the meeting did and did not evidence, and every figure is checked against the transcript. Reports export to PDF as an internal coaching record, never shared with the client. By our estimate, reviewing a meeting drops from about an hour to minutes.

The AI work runs through your firm's own Claude or ChatGPT account, so transcripts are processed by the AI provider you chose, under your own account. That is something to cover in your DPIA. Asclto helps you review and evidence meetings. It does not decide what your recording obligations are, and responsibility for meeting them stays with the firm. For more on the coaching side, see reviewing every recorded client meeting.

Frequently asked questions

Do financial advisers have to record face-to-face client meetings?

The SYSC 10A rules do not require face-to-face meetings to be audio-recorded. SYSC 10A.1.13R says the content of relevant face-to-face conversations "may be recorded by using written minutes or notes."

Does COBS 11.8 still apply to recording?

No. COBS 11.8 was last in force on 2 January 2018 and the rules moved to SYSC 10A. Procedures that still cite COBS 11.8 should be updated.

How long must recordings be kept?

Records kept under SYSC 10A must be retained for five years and, where requested by the FCA, for up to seven years. Other records, such as suitability records under COBS 9.5, have their own periods, so set your retention policy with all of them in mind.

To see Asclto review a recorded meeting, read about Asclto or book a twenty-minute demo with Adam Booth on Microsoft Teams. It runs live on a demo firm with its own clients and meetings, so there is nothing to prepare.