Yearly suitability assessment checklist for advisers: from the invitation to the file note

An advice firm that charges for ongoing service owes each client a review, and the proof that it happened is a handful of dated documents. This list follows one client's review from the invitation, eight weeks before it is due, to the file note and next year's task. It is written for the adviser, paraplanner or administrator in a small FCA-regulated firm who prepares reviews and has to show later that each one was delivered. Use one list for each client each year. The steps for a client who does not reply sit in their own group, so skip them when the client books a meeting.

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Annual review checklist for advice firms

Tick each step as it is done. The ticks are kept in this browser only, so you can come back to the list; nothing is sent anywhere.

Eight weeks before the review is due

Set the due date: twelve months from the last delivered review Check the client agreement for the review frequency promised and what the fee pays for Send the invitation with the questionnaire, eight weeks before the due date File a dated copy of the invitation on the client record the day it goes Send letters of authority to each provider for valuations and charges

If the client does not reply

No reply after two weeks: phone the client, then email the same day Three weeks later: post a final offer for the year, signed by the adviser, with a reply-by date Before treating silence as disengagement, check the address, the phone number and the file for vulnerability No reply by the reply-by date: the adviser records the decision on the charge, with the reason

Preparing the pack

Update the fact find from the returned questionnaire: circumstances, objectives, risk and capacity for loss Chase any provider that has not answered at 10, 15 and 20 working days Put the year's actual costs and charges in the pack, in pounds and as a percentage If the firm uses a cashflow plan, refresh it from the updated fact find

The review meeting

If the meeting is recorded, tell the client before the recording starts Say the date, where you are and who is present once the recording is running Ask what has changed, including health and family, and record any sign of vulnerability Record the adviser's conclusion on whether the investments still suit the client

After the meeting

Check the meeting note the same day against the six points, and add the adviser's name and the date Send the written review; after the first report it need only cover what has changed Have the adviser read and sign anything a tool or a colleague drafted before it goes to the client Write the file note: invitation date, what was sent, meeting date and the outcome File the recording and the corrected note, and keep them for the period in the firm's schedule Create next year's review task now, with this year's evidence attached

Copy what is left Print the list Clear the ticks

A working list, not a certificate and not advice: the rule behind each step, with its source, is set out below. Regulated work: the adviser, and the compliance function where the firm's procedures require it, reviews and signs every client-facing document and every suitability decision; the AI assistant prepares, checks and chases, it never advises.

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Eight weeks before the review is due

Set the due date: twelve months from the last delivered review. COBS 9A.3.9R requires a firm providing a periodic suitability assessment to review its recommendations at least annually. CP26/10 proposes periodic reviews in place of annual ones, but it is a consultation and no policy statement had been published by 1 October 2026. Source: FCA Handbook COBS 9A.3.9R, read 1 October 2026; FCA CP26/10, 25 March 2026. The working is in CP26/10 for small advice firms.

Check the client agreement for the review frequency promised and what the fee pays for. COBS 9A.3.8R requires the firm to disclose the frequency and extent of the periodic assessment, so the agreement is what this year is measured against. Leave the word annual in place until final rules and a start date are published. Source: FCA Handbook COBS 9A.3.8R, read 1 October 2026. The working is in CP26/10 for small advice firms.

Send the invitation with the questionnaire, eight weeks before the due date. Our suggested sequence, which is not an FCA timetable, is three contacts over eight weeks by at least two channels. For a review due on 1 December 2026 the invitation goes on 6 October. Source: our sequence for one review year. The working is in Client not responding to annual review invitations.

File a dated copy of the invitation on the client record the day it goes. A year counts as delivered only with three dated items on file: the invitation, the questionnaire or valuation sent, and the meeting or written review with its outcome. A diary entry alone is not a review. Source: FCA, ongoing financial advice services review, 24 February 2025. The working is in The FCA's ongoing advice review, and the evidence pack a small firm needs for every client since 2018.

Send letters of authority to each provider for valuations and charges. The valuation and charges the review depends on come from providers. Send the authority when the invitation goes, and ask that any defect in it be raised straight away, not at the first chase. Source: our chase template for providers. The working is in Letter of authority and document chase email template.

If the client does not reply

No reply after two weeks: phone the client, then email the same day. The FCA sets no number of chasers. It looks for reasonable and proportionate attempts to engage, and in its February 2025 review 15% of promised reviews were declined or went unanswered. Source: FCA, ongoing financial advice services review, 24 February 2025. The working is in Client not responding to annual review invitations.

Three weeks later: post a final offer for the year, signed by the adviser, with a reply-by date. The third letter offers a meeting, a written review or stopping the service. COBS 6.1A.22R allows an ongoing charge only where the client can cancel without penalty and without giving a reason, and the letter says so. Source: FCA Handbook COBS 6.1A.22R. The working is in Client not responding to annual review invitations.

Before treating silence as disengagement, check the address, the phone number and the file for vulnerability. The FCA's own examples of why a client might miss a review are illness and bereavement, and CP26/10 notes that disengagement may be temporary. It considered and rejected a rule to offboard clients after 24 months. Source: FCA CP26/10, 25 March 2026. The working is in Client not responding to annual review invitations.

No reply by the reply-by date: the adviser records the decision on the charge, with the reason. The FCA's February 2025 review lists as good practice policies to stop collecting fees where a client has not engaged for a period of time. Silence only counts as not engaged if the dated offers are on file. Source: FCA, ongoing financial advice services review, 24 February 2025. The working is in The FCA's ongoing advice review, and the evidence pack a small firm needs for every client since 2018.

Preparing the pack

Update the fact find from the returned questionnaire: circumstances, objectives, risk and capacity for loss. COBS 9A.2.1R requires information on the client's knowledge and experience, financial situation including ability to bear losses, and objectives including risk tolerance. COBS 9A.2.10R requires procedures to keep it up to date in an ongoing relationship. Source: FCA Handbook COBS 9A.2.1R and 9A.2.10R, read 1 October 2026.

Chase any provider that has not answered at 10, 15 and 20 working days. At 20 working days the chase to a provider becomes a complaint under the provider's own procedure, not a fourth email. A file note of three dated chases shows a review that was late, not one that was never attempted. Source: our chase rhythm; FCA, ongoing financial advice services review, 24 February 2025. The working is in Letter of authority and document chase email template.

Put the year's actual costs and charges in the pack, in pounds and as a percentage. COBS 6.1ZA requires all costs and charges to be added together and shown in cash and as a percentage, with the cumulative effect on return, before the service starts and at least annually afterwards. The yearly version goes in the review pack. Source: FCA Handbook COBS 6.1ZA. The working is in Adviser charging illustration calculator.

If the firm uses a cashflow plan, refresh it from the updated fact find. A cashflow plan is only as current as the fact find behind it. Where the tool is fed from the back office, an error in the client record arrives in the plan unless someone looks. Source: our price check of two cashflow tools. The working is in FE CashCalc vs Voyant AdviserGo.

The review meeting

If the meeting is recorded, tell the client before the recording starts. SYSC 10A.1.11R requires clients to be told before any service is provided that conversations will be recorded. The rule asks for notice, not permission, though a firm can choose to ask. Compliance decides which meetings fall inside the rule. Source: FCA Handbook SYSC 10A.1.11R. The working is in Recording client meetings with an AI note taker.

Say the date, where you are and who is present once the recording is running. SYSC 10A.1.16R lists what the record of a relevant face-to-face conversation must include: date and time, location, attendees, who initiated the meeting and the details of any client order. Software cannot note a location nobody mentioned. Source: FCA Handbook SYSC 10A.1.16R. The working is in Recording client meetings with an AI note taker.

Ask what has changed, including health and family, and record any sign of vulnerability. Vulnerability considered and recorded is one of the nine points our file check looks for. Health details are special category data under Article 9 of the UK GDPR, and so is a recording or transcript that contains them. Source: UK GDPR Article 9; FCA FG21/1. The working is in Recording client meetings with an AI note taker.

Record the adviser's conclusion on whether the investments still suit the client. Where a firm has told the client it will assess suitability periodically, the periodic report must contain an updated statement of how the investments meet the client's preferences, objectives and other characteristics. The judgement is the adviser's alone. Source: FCA Handbook COBS 9A.3.2R(4), read 1 October 2026.

After the meeting

Check the meeting note the same day against the six points, and add the adviser's name and the date. The ICO says an organisation using an AI tool for meeting notes must check that the outputs are accurate and correct anything that is not. The note needs the date and time, location, attendees, who asked for the meeting and any instruction. Source: ICO innovation advice, previously asked questions; FCA Handbook SYSC 10A.1.16R. The working is in Recording client meetings with an AI note taker.

Send the written review; after the first report it need only cover what has changed. COBS 9A.3.3R(4) says reports after the first need only cover changes in the services or instruments and in the client's circumstances. If the review leads to a new recommendation, run that report through the file check before the adviser signs. Source: FCA Handbook COBS 9A.3.3R(4), read 1 October 2026. The working is in Suitability report file check.

Have the adviser read and sign anything a tool or a colleague drafted before it goes to the client. The FCA has no AI-specific rules: the existing framework applies, and the adviser is responsible for the recommendation however it was drafted. A report drafted by a tool and signed by an adviser is the adviser's report. Source: FCA AI Update, April 2024. The working is in AI and client data in an advice firm.

Write the file note: invitation date, what was sent, meeting date and the outcome. This note is what makes the year count as delivered. The FCA found reviews delivered in 83% of promised cases and asked firms to look back to 2018, so each year's evidence has to be findable years later. Source: FCA, ongoing financial advice services review, 24 February 2025. The working is in The FCA's ongoing advice review, and the evidence pack a small firm needs for every client since 2018.

File the recording and the corrected note, and keep them for the period in the firm's schedule. SYSC 10A.1.14R requires records in scope to be kept for five years, or up to seven where the FCA asks, and given to the client on request. A complaint can reach the ombudsman six years after the event, or later. Source: FCA Handbook SYSC 10A.1.14R and DISP 2.8.2R. The working is in How long must a financial adviser keep client files? The FCA minimum for each type of record, and a retention schedule to copy.

Create next year's review task now, with this year's evidence attached. Fixing the process means a review task for each client each year, created at the last review. A year with a fee and no evidence on file is the one the FCA asked firms to consider redress for. Source: FCA, ongoing financial advice services review, 24 February 2025. The working is in Ongoing service tracker for advice firms.

How to use the list

Keep the finished list on the client record with the year's evidence: the invitation, the questionnaire or valuation, the meeting note and the written review, each dated. Tick a step that did not apply, such as the chasing steps for a client who replied at once, so the list shows that somebody decided. Where the client did not engage, the list and the three dated offers are what the adviser works from when recording the decision about the charge. Clear the ticks before starting the next client.

A ticked list is a record that the steps were done, not proof that each was done properly. The list covers the points our guides and the official pages named above set out; it is not every duty a firm has. The adviser, and compliance where the firm's procedures require it, reviews and signs anything a tool drafts, and this page is general information, not regulatory or financial advice.

Overlyft sets up AI assistants for financial advisers and mortgage brokers: they prepare drafts for a person to approve. They do not tick off any of these steps for you, and you can do every one without them.