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Annual reviews and ongoing service
Client not responding to annual review invitations: what the FCA has said, three letters to copy, and when to stop the ongoing charge
The FCA sets no number of chasers for a client who ignores review invitations. What it has said, three letters to copy with dates, and when to stop the fee.
No FCA rule says how many times to chase a client who ignores a review invitation, or when to stop charging them. What the FCA has said is that it looks for "reasonable and proportionate attempts to engage", and that it expects the firm to have a policy that includes stopping the fee.
Free tool
Ongoing service invitation and chaser letter maker
Enter the client, the date the yearly meeting is due and the yearly charge. The three letters come out with their dates worked back from the due date: 8 weeks, 6 weeks and 3 weeks before, and a reply-by date 1 week before.
- Attach the questionnaire to letter 1 and enclose it with letter 3.
- Make the phone call before you send letter 2; the letter says you tried to call that day.
- If a contact went out on a different day from the one shown, correct the date in the text before you send.
- Check the yearly charge against the client agreement, and that the agreement lets the client cancel as letter 3 says.
- Keep a copy of each contact with its date, its channel and who made it.
The rule this rests on: FCA ongoing advice review, 24 February 2025 (reasonable and proportionate attempts to engage); COBS 9A.3.9R; COBS 6.1A.22R. A draft to check and adapt, not legal advice. 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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What the FCA has said
| Date | Where | What it says |
|---|---|---|
| 24 February 2025 | Ongoing advice review | In 15% of cases, clients "either declined or did not respond to the firm's offer of a review". Where firms "have made reasonable and proportionate attempts to engage" without success, redress is "less likely", but "a firm should have considered whether an ongoing service is in a client's best interest if they've persistently not engaged" |
| 24 February 2025 | Same review, good practice | "Policies in place to stop collecting fees where a client had not engaged with the service for a period of time" |
| 25 March 2026 | CP26/10, paragraph 3.21 | "We expect firms to have policies for what to do when client disengagement means they are not receiving the service they are paying for. This should include stopping collecting fees for ongoing services." |
| 25 March 2026 | CP26/10, paragraph 3.28 | The FCA expects firms to be "mindful that continued charging without meaningful delivery would ultimately breach their Consumer Duty obligations" |
CP26/10 is a consultation. It closed on 22 May 2026, and on 1 October 2026 the FCA's page for it showed no policy statement, so its proposed guidance on disengaged clients is not in force. The paragraphs quoted describe what the FCA says it already expects under the Consumer Duty.
The paper has no number in it either. The FCA considered "requiring firms to offboard clients after 24 months of non-engagement" and rejected it, because a fixed period may "fail to account for legitimate reasons why a client might miss a review (such as illness or bereavement)". Our guide to CP26/10 for small firms covers the rest.
Two rules are in force today. COBS 9A.3.9R requires a periodic suitability assessment "at least annually". COBS 6.1A.22R allows an ongoing charge only where the client can cancel the service "without penalty and without requiring the retail client to give any reason", and the third letter says so.
A sequence for one review year
This is our suggestion, not an FCA timetable: three contacts over eight weeks, by at least two channels. The example client's review is due on Tuesday 1 December 2026, and they pay 0.75% a year on £320,000, which is £2,400.
| Step | When | Example date | How |
|---|---|---|---|
| 1. Invitation | 8 weeks before the due date | Tuesday 6 October 2026 | Email with the questionnaire |
| 2. Reminder | 2 weeks later | Tuesday 20 October 2026 | Phone call, then email the same day |
| 3. Final offer for the year | 3 weeks after that | Tuesday 10 November 2026 | Post, signed by the adviser |
| Reply-by date in letter 3 | 2 weeks later | Tuesday 24 November 2026 |
The three letters
Letter 1, the invitation:
Dear [name],
Your yearly review is due by [due date]. It is part of the ongoing service you pay for, and it is how we check that your investments still suit you.
Please choose a time using [link or phone number] and return the short questionnaire attached, so that we can prepare. We can meet in person, by video or by phone.
Letter 2, the reminder:
Dear [name],
We wrote on [date of letter 1] about your yearly review and tried to call you today.
If a meeting is difficult at the moment, we can carry out the review in writing from the questionnaire, or later. If something has changed for you or your family, tell us. Please reply by [date].
Letter 3, the final offer for the year:
Dear [name],
We contacted you on [date 1] and [date 2] about your yearly review and could not reach you. Without up-to-date information from you we cannot carry it out.
You pay [£2,400] a year for our ongoing service, and the review is the main part of it. We do not want you to pay for a service you are not using. Please tell us by [reply-by date] which of these you would like:
- Book the review, in person, by video or by phone.
- Have the review in writing, using the enclosed questionnaire.
- Stop the ongoing service. You can cancel at any time, without penalty and without giving a reason.
If we do not hear from you by that date, I will decide whether the service and its charge should continue, and I will write to you with the outcome.
[Adviser's name and signature]
Match the wording to your client agreement and have compliance approve it before first use.
What goes on file
Keep a copy of each contact with its date, its channel and who made it. On the due date the adviser adds one note:
Review offered on 6 October, 20 October and 10 November 2026 by email, phone and post. No reply by 24 November 2026. Recorded as not engaged. Charge: [continues or stops], decided by [adviser] on [date] because [reason].
Silence only counts as not engaged if the offers are on file. The evidence pack guide explains why, and the ongoing service tracker counts the years for one client.
When to stop the charge
The FCA gives no period, so the firm's written policy has to. Three points to settle in it:
- After one silent year. Record the decision and its reason, and open the next cycle with a different channel.
- After a second year running. The February 2025 review says that where a client has declined "over a number of years, firms should discuss with the client whether continuing with the service is still in their best interest". Name who decides, and the date by which the charge stops if nothing changes.
- Before stopping or ending the service. Check the address, the phone number and the file for signs of vulnerability. The FCA's own examples of a missed review are illness and bereavement, and CP26/10 notes that "disengagement may be temporary".
Who does what
Overlyft can set up an AI assistant to prepare the first two contacts on the firm's approved wording and keep the dated record for each year. It does not decide on a charge or write to a client about one, so the third letter and the decision are the adviser's. The adviser, and compliance where the firm's procedures require it, reviews and signs anything a tool drafts. This page is general information, not regulatory or financial advice.
Short answers from this page
How many times does a financial adviser have to chase a client who ignores annual review invitations before stopping the fee?
The FCA sets no number and no cut-off. Its 24 February 2025 review looks for reasonable and proportionate attempts to engage and lists policies to stop collecting fees from clients who have not engaged as good practice. In CP26/10, which is not in force, it considered and rejected a rule to offboard clients after 24 months. The firm's own written policy sets the period.
Source: FCA, ongoing financial advice services review, 24 February 2025; FCA CP26/10, 25 March 2026, paragraphs 3.21 to 3.28
When should an advice firm send the invitation, the reminder and the final letter before a client's annual review is due?
The FCA sets no timetable. One workable sequence is three contacts over eight weeks: an email invitation eight weeks before the due date, a phone call and reminder email two weeks later, and a posted final offer three weeks after that, with a reply-by date two weeks on. For a review due on 1 December 2026 that is 6 October, 20 October, 10 November and 24 November.
Source: Our own sequence; FCA ongoing advice review, 24 February 2025 (reasonable and proportionate attempts to engage)
Every short answer for financial advisers and mortgage brokers
Where this comes from: FCA, ongoing financial advice services multi-firm review, 24 February 2025 (findings, good practice, next steps for firms), read in a browser 2026-10-01; FCA CP26/10, Simplifying the pensions and investment advice rules, 25 March 2026, paragraphs 3.21 to 3.28 and cost benefit analysis paragraph 59 (PDF read 2026-10-01), and the FCA's CP26/10 web page (closed, no policy statement, read 2026-10-01); FCA Handbook COBS 9A.3.9R and COBS 6.1A.22R, read in a browser 2026-10-01. The contact sequence and the letters are our own suggestion, not an FCA timetable. General information, not regulatory advice.
AEO Lookup editorial team
We write practical guides for people who run small UK firms, and we check every fact against its source on the date shown. Read how we review, or tell us if something has changed.
