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Annual reviews and ongoing service

Ongoing service tracker for advice firms: when the next review is due, how many were promised and not delivered since 2018, and what the undelivered fees come to

Enter the service start, last delivered review, reviews delivered and declined, the portfolio and the charge to see the next due date and the undelivered fees.

The FCA's February 2025 review of ongoing advice found that in 83% of cases where a review was promised it was delivered, in 15% the client declined or did not engage, and in under 2% the firm made no effort. It asked firms to look back to 2018 and consider redress. Those are sector numbers; the firm's exposure is a per-client sum, and this tracker does the sum for one client at a time.

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Ongoing service tracker: when the next review is due, how many were promised and not delivered since the start, and what the undelivered fees come to

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What it counts

Completed service years since the start date (or 3 January 2018, the MiFID II date the FCA uses as the look-back, if the service started earlier). Against that: reviews delivered, meaning a meeting or written review the file shows, and reviews declined, meaning the offer and the client's decline are both on file with dates. The remainder is undelivered: a year in which the fee was taken and the file shows neither a review nor a recorded decline.

The ongoing charge at today's value gives the fee for each undelivered year; the tracker adds simple interest at the rate your redress policy uses, assuming the undelivered years were the most recent (the lowest figure; earlier years attract more). The FOS applied 8% simple to complaints referred before 1 January 2026 and still does for late payment; for referrals from that date its default tracks the Bank of England base rate plus one point. The rate is an input because the firm's policy, not the tracker, decides it.

What the FCA said about redress

That firms should consider whether redress is appropriate, that it may be partial where some service was delivered, and that it is fact dependent. The tracker gives the firm the facts for one client; the decision is the firm's, with its compliance function, and the evidence pack guide sets out what the file has to hold before the decision is made.

The next review date

Twelve months from the last delivered review, because the rule today is at least annual for MiFID business. CP26/10, published on 25 March 2026, proposes periodic reviews in place of annual ones and clarifies that firms may charge for ongoing related services linked to an earlier recommendation; it also sets out what the FCA expects where clients do not engage. It is a consultation, not a rule, so the tracker counts twelve months until the policy statement says otherwise.

The evidence per year

For a year to count as delivered the file holds the invitation with its date, the questionnaire or valuation sent, and the meeting or written review with its date and outcome. For a year to count as declined it holds the offer, the client's decline and the follow-up offer, each dated. A year with a fee and none of those is the one the FCA's figures describe. The adviser charging illustration shows what that fee is in pounds over the years the client has paid it.

Running it across the book

One client takes a minute. A book of three hundred takes a list from the back office: service start, last review, count delivered, count declined, value, charge. Most back-office systems hold the first and the last two; the review counts are the gap, because reviews are recorded as tasks or notes rather than as a count, and the look-back is the work of pulling them into a column. That is the work an AI Review Coordinator set up by Overlyft does: it builds the column from the system's review records, flags every client with an undelivered year or an overdue next review, and drafts the invitation for the next one.

In the firm

The Review Coordinator books reviews, sends the pre-review questionnaire, pulls valuations and prepares the pack, and records the outcome or the decline with dates, so that the file answers the FCA's question without a look-back. It never decides on redress, never changes a fee and never writes to a client about either; those are the adviser's and the compliance function's. Not legal or regulatory advice.

Short answers from this page

Does a firm have to refund ongoing advice fees if a review was not delivered?

The FCA expects the firm to consider it, case by case, and says redress may cover only part of the charges where some service was delivered. One undelivered year at 0.75% on a £320,000 portfolio is £2,400 before interest. The decision is the firm's, with its compliance function, on the evidence in the file.

Source: FCA, 24 February 2025

Every short answer for financial advisers and mortgage brokers

Where this comes from: FCA, ongoing financial advice services review, 24 February 2025 (83% delivered, 15% declined or did not engage, under 2% no effort; look back to 2018; consider redress, which may be partial); COBS 9A.3.9R (periodic suitability assessment at least annually); FCA CP26/10, 25 March 2026 (periodic in place of annual; not in force); FOS interest guidance (8% simple before 1 January 2026 and for late payment; base rate plus one point for referrals from that date). Read 2026-10-01. Tested in headless Edge 2026-10-01.

AL

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.

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