# CP26/10 for small advice firms: what the FCA proposed on 25 March 2026, what the rule still is today, and what to change before the policy statement

> CP26/10 proposes periodic instead of annual suitability reviews. It is not in force. What the rule is today, what was proposed, and six steps for a small firm.

- Page to cite: https://aeolookup.com/financial-advisers/cp26-10-periodic-suitability-small-advice-firm-what-to-change/
- Publisher: AEO Lookup (https://aeolookup.com/)
- Section: Financial advisers and mortgage brokers, Annual reviews and ongoing service
- Published 1 October 2026
- Key fact: On 1 October 2026 the annual rule is still in force: COBS 9A.3.9R requires a firm providing a periodic suitability assessment to review its recommendations at least annually. CP26/10 (published 25 March 2026, closed 22 May 2026) proposes periodic reviews with no fixed interval, having considered and rejected an 18 or 24 month minimum, and the FCA aims to publish a policy statement in Q4 2026.
- Sources: FCA CP26/10, Simplifying the pensions and investment advice rules, 25 March 2026 (paragraphs 1.23, 1.25, 2.53 to 2.57, 3.1, 3.8 to 3.10, 3.14, 3.17, 3.21 to 3.28; cost benefit analysis paragraphs 57 and 59), PDF and web page read 2026-10-01; FCA Handbook COBS 9A.3.8R, 9A.3.9R and 9A.3.10R, read 2026-10-01; FCA ongoing financial advice services review, 24 February 2025, read 2026-10-01. General information, not regulatory advice.

A firm that promised its clients an annual review still owes them one. CP26/10 is a consultation, the FCA has not published final rules, and on 1 October 2026 the Handbook still says what it said before: under COBS 9A.3.9R, "a firm providing a periodic suitability assessment must review the suitability of the recommendations given at least annually". COBS 9A.3.10R says the same for insurance-based investment products.

## The dates

| Date | What happened |
|---|---|
| 24 February 2025 | The FCA published its review of ongoing advice services and said it would look again at the rules |
| 25 March 2026 | CP26/10 published |
| 22 May 2026 | Consultation closed |
| Q4 2026 | The FCA "aim[s] to publish a Policy Statement", though it says this "depends on the extent of feedback" |

When we read the FCA's consultation page on 1 October 2026 it said the consultation had closed and that a policy statement would follow once responses had been considered. It gave no date. The draft instrument at the back of the paper leaves its start date blank ("This instrument comes into force on [date]"), so there is no start date to plan around yet.

## Today's rule beside the proposal

| Subject | Rule on 1 October 2026 | CP26/10 proposal |
|---|---|---|
| How often | At least annually for MiFID business and insurance-based investments (COBS 9A.3.9R, 9A.3.10R) | Remove the annual requirement; the firm sets "the most appropriate review frequency based on an assessment of customer needs and circumstances" (paragraph 3.14) |
| Telling the client | Disclose the frequency and extent of the periodic assessment (COBS 9A.3.8R) | A new COBS 9C.4: clients must be clear on the scope of the ongoing service, including review frequency, for all investment advice in scope (3.17) |
| Charging | Ongoing charges need an ongoing service (COBS 6.1A.22R) | Firms may charge for services related to earlier advice without a new recommendation each time; payments for the initial advice stop once it is paid off (3.8, 3.10) |
| Clients who do not engage | No specific Handbook rule; the Consumer Duty applies | New guidance, no new standard; policies "should include stopping collecting fees" (3.21, 3.24) |
| Suitability report | Timing differs by product | One duty to provide it before the transaction; concise; compliance records "retained separately from the suitability report" (2.54, 2.57) |

Every entry in the right-hand column is a proposal. None of it is a rule.

## "Periodic" has no number in it

The FCA looked at fixing a longer interval and chose not to. Its cost benefit analysis says it considered "shifting from an annual review to one every 18 or 24 months" and rejected it, because a fixed minimum "may inadvertently encourage firms to treat the minimum as the default". It also considered requiring firms to offboard clients "after 24 months of non-engagement" and rejected that as well.

So if the proposal becomes a rule, the firm chooses the interval for each client or each service tier, writes down why, tells the client, and charges a fee that matches. The paper ties frequency to price: it describes services with less frequent reviews "which could be priced accordingly" (paragraph 3.12), and says the firm "must be able to show evidence that the service provided is commensurate with the fee charged" (3.18).

The scale explains the attention. The FCA puts about 80% of adviser charge revenue down to ongoing services, paid by around 3.7 million clients (paragraph 3.1).

## A worked example

A firm has 180 clients on ongoing service. Today that is 180 reviews a year, or 15 a month.

Suppose the final rule allowed it, and the firm judged that 60 clients with simple accumulation plans needed a review every two years. Those 60 would need 30 reviews a year instead of 60. The firm's total falls from 180 to 150, or 12.5 a month.

That is 30 reviews saved, and 60 clients whose fee has to be looked at again. Paragraph 3.20 of the paper asks for views on safeguards against firms "reducing service quality without a corresponding reduction in price", and the same fee for half the reviews is that case.

## What to do now, and what to leave

1. **Keep delivering annual reviews.** The rule is in force and the client agreement promises a frequency. The [evidence pack for the FCA's ongoing advice work](https://aeolookup.com/financial-advisers/fca-ongoing-advice-review-evidence-pack-small-firm/) is unaffected, because the look-back is on the rule as it stood.
2. **Write the disengagement policy now.** The paper says the FCA already expects firms to have policies for clients who pay and do not engage, and that those policies should include stopping fees. Set out how many offers are made, in which formats, over what period, and who decides to stop the charge. The [ongoing service tracker](https://aeolookup.com/financial-advisers/ongoing-service-review-tracker-undelivered-fees/) shows which clients that covers.
3. **Sort the client list, without changing anything.** Mark each client by what they need: drawdown or accumulation, complex or simple, vulnerable or not. This is the "assessment of customer needs and circumstances" the proposal asks for. It can be done now and changes nothing for the client.
4. **Separate the report from the record.** Today's rule sets no length. COBS 9.4.7R lists what the report must at least contain: the client's demands and needs, why the recommendation is suitable, any possible disadvantages, and for a life policy a personalised recommendation. The [suitability report file check](https://aeolookup.com/financial-advisers/suitability-report-file-check-cobs-9-4-7/) tests for them.
5. **Leave the client agreements alone.** Do not reword "annual" to "periodic" or reprice a tier until the final rules and their start date are published. The policy statement can differ from the consultation.
6. **Put a date in the diary.** Check the FCA's CP26/10 page in the first week of each month until the policy statement appears, then read the commencement date before anything else.

## Who signs what

The adviser, and compliance where the firm's procedures require it, reviews and signs anything a tool drafts, including review invitations and reports. Overlyft ![](https://aeolookup.com/img/d/ours-badge.png) can set up an AI assistant to prepare the client list in step 3 and the invitations for the adviser to check. This page is general information taken from the FCA's published documents; it is not regulatory or financial advice.

## Short answers from this page

**Will CP26/10 let advice firms move every client to a review every 18 or 24 months?** No. CP26/10, published on 25 March 2026, proposes periodic reviews with no fixed interval. The FCA considered an 18 or 24 month minimum and rejected it, so the firm would set a frequency for each client and justify it. The proposal is not in force: on 1 October 2026 COBS 9A.3.9R still required a review at least annually.

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General information for UK small firms, not legal, tax or financial advice.