Suitability at scale: how the FCA’s advice review could reshape the UK advice gap

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The UK is trying to get more people investing—openly, and at scale. The government-backed Invest for the Future campaign is the public-facing part of that push, designed to make investing feel “for people like me,” not just for the financially confident. At the same time, targeted support— the FCA-backed alternative sitting between guidance and full advice—is moving from concept to reality, but the FCA’s CP26/10 consultation on simplifying the pensions and investment advice rules aims to narrow the advice gap even further. What are the implications for financial advisers and solution providers?
 

Why the stubborn gap between saving and investing?

 
The Invest for the Future campaign is deliberately practical. It is using real-world storytelling and outreach (including a campaign mascot and in-person activations) to normalise the idea of investing as a mainstream behaviour rather than an elite niche.
 
The timing is not accidental. Inertia remains powerful: recent research by Lubbock Fine suggests that only 10.4% of cash ISA holders also have a stocks and shares ISA—meaning the jump from ‘saving’ to ‘investing’ is still not happening for most people by default.
 
This reveals a gap part driven by lack of experience, lack of trust and affordability—not only of the advice needed to understand more complex investment products but also of the surplus savings beyond emergency reserves that can reasonably be locked into investments for the next five years or longer. The next growth wave for financial advisers and asset managers depends less on product innovation and more on closing that gap. Much of the FCA’s current advice review is ultimately focused on reducing the advice gap at scale.
 

The new advice continuum and the future of accessible advice

 
The FCA’s Advice Guidance Boundary work is trying to create a genuine continuum: guidance, targeted support, simplified/limited-scope advice, and full financial advice. That matters because the ‘advice gap’ is not only about demand; it is also about delivery capacity and cost-to-serve. For advice firms, this points to a new competitive baseline. Clients will increasingly expect help to be available at different price points and in different formats—especially for simpler goals.
 
Targeted support is just one part of it, and four firms have already announced plans to make it available to their clients. A common thread throughout these early offerings is helping savers and investors engage more easily with a broader set of solutions without needing to be investment experts: 
 
 

Periodic suitability reviews will drive needs-based servicing

 
Beyond targeted support, the FCA is taking steps to make financial advice more accessible and easier to deliver at scale. One proposal is commercially significant: moving away from a required annual suitability review toward periodic reviews based on clients’ needs. The FCA’s logic is simple: for some client segments, annual reviews may still make sense; for others, a less frequent review cycle—priced accordingly—could be both suitable and more affordable.
 
This does not automatically mean fewer client touchpoints. It means firms can design servicing around life events and need (and evidence that decision), rather than a fixed calendar. For many firms, that is an operational shift: segmentation, monitoring, and clear disclosure become central.
 

“Sufficient information” reshapes suitability assessments

 
CP26/10 also proposes moving from collecting “necessary” information to “sufficient” information for suitability assessments—explicitly to reduce defensive, one-size-fits-all factfinding and enable different advice services.
 
The consultation signals that, for a straightforward recommendation (for example, investing a lump sum into a diversified stocks & shares ISA), suitability information will often focus on:
 
 

A clearer risk framework for simplified financial advice

 
The FCA proposes one “attitude to risk” concept (the risk a client is willing to take to meet objectives), and explicitly says firms do not always need complex tools or detailed questionnaires to assess it. Additionally, the FCA indicates firms can take a proportionate approach when assessing a client’s ability to bear losses. 
 
As for investment knowledge and experience, CP26/10 proposes clarifying that firms do not always need to assess a customer’s knowledge and experience before a recommendation, where the envisaged product is reasonably identified as one whose target market includes clients with no investing experience.
 
That matters for firms building simplified propositions: it reduces friction for entry-level mainstream products, while preserving the expectation that more complex or higher-risk recommendations require deeper assessment.
 

The advice gap is shrinking in more ways than one

 
The Invest for the Future campaign is trying to normalise investing. Targeted support is turning into reality. And CP26/10 is aiming to make advice delivery more proportionate—so firms can profitably serve more people without lowering standards.
 
For institutional investors, this change is important: broader retail participation and more patient capital depend on trust and accessible support, not only on product supply.
 
For financial advisers, the opportunity is to build tiered service propositions that are clearer, cheaper where appropriate, and easier to evidence.
 
And for advice technology—including AI—the business case is concrete. The firms that win will not be the ones producing the most paperwork. They will be the ones that produce clearer client outputs faster, supported by robust evidence trails—making compliant advice viable at the margins where today it is simply too expensive.

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