# The FCA's ongoing advice review, and the evidence pack a small firm needs for every client since 2018 > The FCA found 83% of promised reviews delivered, 15% declined, under 2% not attempted. What it asked, what CP26/10 proposes, the evidence a firm needs. - Page to cite: https://aeolookup.com/financial-advisers/fca-ongoing-advice-review-evidence-pack-small-firm/ - Publisher: AEO Lookup (https://aeolookup.com/) - Section: Financial advisers and mortgage brokers, Annual reviews and ongoing service - Published 1 October 2026 - Key fact: The FCA's review of ongoing advice found that reviews were delivered in 83% of promised cases, declined or not engaged with in 15%, and not attempted in under 2%; it asked firms to look back to 2018 and consider redress, which may be partial; and thirteen months later CP26/10 proposed replacing the annual review with a periodic one, so the look-back is on the old rule and the future is on a new one. - Sources: FCA, ongoing financial advice services review, 24 February 2025; FCA CP26/10, Simplifying the pensions and investment advice rules, 25 March 2026 (periodic reviews, charging for ongoing related services, expectations where clients do not engage); COBS 9A.3.9R (periodic assessment at least annually); read 2026-10-01. Not regulatory advice; the firm's compliance function owns the look-back. On 24 February 2025 the FCA published its review of ongoing financial advice services. In the cases it looked at, suitability reviews promised to clients were delivered in 83%; in 15% the client declined the review or did not engage; in under 2% the firm had made no effort. The FCA asked firms to look back to 2018, the MiFID II date, and to consider whether redress was appropriate, noting that it may be partial where some service was delivered. Thirteen months later, on 25 March 2026, CP26/10 proposed replacing the annual review requirement with a periodic one. This guide is for the small firm doing the look-back itself. ## The three buckets, per client-year For every client who has paid an ongoing charge in any year since 2018, each year falls into one of three buckets, and the file has to show which. **Delivered.** The invitation with its date; the questionnaire or valuation sent; the meeting or written review with its date and the outcome recorded. All three, dated. A diary entry alone is not a review. **Declined or did not engage.** The offer with its date, the client's decline or silence, and the follow-up offer. The FCA's 15% is this bucket, and it is only this bucket if the offers are on file. A client who was never asked is in the third bucket however disengaged they were. **Not delivered.** A fee and none of the above. This is the under 2% in the FCA's sample, and in a small firm it is usually not neglect but a year when the adviser was ill, a staff member left, or the back office changed and the review tasks did not migrate. The [ongoing service tracker](https://aeolookup.com/financial-advisers/ongoing-service-review-tracker-undelivered-fees/) does the arithmetic for one client; the look-back is the same arithmetic for the book. ## The order to do it in 1. Pull the list: every client with an ongoing charge, the start date, the charge, the value, from the back office. 2. For each, count the service years since the later of the start and 3 January 2018. 3. For each year, find the evidence and assign the bucket. Record where the evidence is, not just that it exists. 4. List the not-delivered years with the fee for each. 5. Take the list to the compliance function and decide, client by client, on redress: full, partial or none, with the reason written down. The FCA said the decision is fact dependent; the facts are the list. 6. Fix the process so next year's list is empty: a review task per client per year, created at the last review, with the evidence attached to it. ## What CP26/10 changes, and what it does not The consultation proposes that firms carry out suitability assessments on a periodic rather than annual basis, clarifies that firms may charge on an ongoing basis for related services linked to an earlier recommendation, and sets out what the FCA expects under the Consumer Duty where clients do not engage. The comment period closed in May 2026 and a policy statement is expected later in the year. It does not change the look-back, which is on the rule as it stood. And "periodic" will not mean "whenever": the firm will have to decide the period for each client, say why, and deliver it, which is the same evidence with a different interval. A firm that fixes the process now is ready for both. ## Where clients do not engage The 15% bucket is where the Consumer Duty does the work. A client who declines the review but keeps paying the fee is receiving less than they pay for, and the FCA's view is that the firm has to do something: offer again, offer a different format, review the charge, or end the service. The file shows which, with dates. Charging for a service a client has declined three years running is not a declined review; it is a fee without a service. ## In the firm An AI Review Coordinator set up by Overlyft ![](https://aeolookup.com/img/d/ours-badge.png) builds the per-client, per-year list from the back office's review records and the inbox, flags each not-delivered year and each overdue next review, and drafts the next invitation. An AI File Checker from the same set-up checks that each delivered year has the three dated items. Neither decides on redress, changes a charge or writes to a client about either; the adviser and the compliance function do, and the [charging illustration](https://aeolookup.com/financial-advisers/adviser-charging-illustration-calculator-cumulative-effect/) gives them the fee in pounds for each year in question. General information from the FCA's published documents; not regulatory advice. ## Short answers from this page **What did the FCA's ongoing advice review find?** Published on 24 February 2025, it found that suitability reviews promised to clients were delivered in 83% of cases; in 15% the client declined or did not engage; and in under 2% the firm made no effort. The FCA asked firms to look back to 2018 and to consider redress, which may be partial where some service was delivered. **Is the annual suitability review being replaced?** Proposed, not yet. The FCA's consultation CP26/10, published on 25 March 2026, proposes that suitability be assessed on a periodic basis instead of at least annually, and clarifies that firms may charge for ongoing related services. Until a policy statement changes the rule, a review is due at least every twelve months. --- ![](https://aeolookup.com/img/d/owner-line.png) General information for UK small firms, not legal, tax or financial advice.