FCA Annual Review Changes: What IFA Websites Must Do Now

The FCA annual review changes set out in CP26/10 are the biggest shift in ongoing advice rules since the Retail Distribution Review. The consultation, published on 25 March 2026, proposes ending the mandatory annual suitability review and replacing it with periodic reviews set by adviser judgement. Most IFAs are reading this as a compliance question. It is also a website question, and that side of it is getting very little airtime.

What are the FCA annual review changes in CP26/10?

CP26/10 proposes replacing the mandatory annual suitability review with periodic reviews based on each client's needs. Firms would set their own review frequency using professional judgement, documented against Consumer Duty. The consultation, published on 25 March 2026, closes on 22 May 2026. The FCA expects to publish a Policy Statement by the end of 2026.

The paper does more than drop a calendar rule. It consolidates the suitability requirements in COBS 9 and COBS 9A into a single framework, clarifies that firms can charge for ongoing related services linked to an earlier personal recommendation, and retires the legacy Finalised Guidance FG 17/8 by embedding proportionality directly into the Handbook.

Behind the detail sits a simple message from the FCA. The regulator wants advisers to spend less time producing calendar-driven file notes and more time producing advice that reflects what is actually happening in a client's life.

Source: FCA CP26/10: Simplifying the pensions and investment advice rules.

Why do the FCA annual review changes matter for your IFA website?

If ongoing reviews stop being calendar slots and become needs-driven, clients decide when a review is triggered, not the adviser. That means the channel where clients raise needs matters more than ever. For most firms, that channel is the website. A site that cannot handle a question or capture a prompt will quietly fail the new model.

The commercial stakes are not small. The average ongoing advice fee charged by UK advisers in 2026 is 83 basis points, up from 77 basis points the previous year (NextWealth, 2026). That fee is paid by the client for a service the client has to be able to access. If your website does not surface the service clearly, or does not route questions back to the adviser quickly, the client experience drifts further from the promise.

There is also an enforcement tail to consider. The FCA's 2025 multi-firm review on ongoing financial advice services already flagged that a file note saying "annual review conducted, no changes" is not enough to evidence value. Under the new rules, if a firm cannot show why the chosen review frequency was right for that client, the charge is at risk.

What does responsive advice mean for client communication?

Responsive advice means the review happens when a client has a need. A job change, a bonus, a parent inheriting, markets wobbling. CP26/10 expects firms to document the rationale for each segment's review frequency and evidence that the cadence reflects the client's circumstances. The adviser is no longer driving the calendar.

That shift changes what the website has to do. For existing clients, the site becomes a front door back to the firm between formal touchpoints. For prospects, it becomes the thing they interrogate before booking a first meeting. Both groups are arriving with a specific question in mind rather than "tell me about your services."

IFA Magazine quoted Fundment CEO Ola Abdul describing this shift directly: "The annual review is dead." Whether the exact phrase holds or not, the direction of travel is not in doubt. Firms that built around an annual calendar will need to rebuild around an always-available response path.

For context on how that shift is already changing web behaviour, our earlier piece on what questions visitors actually ask on IFA websites breaks down the most common triggering queries by category.

How should IFAs prepare their website before the rules change?

Use the consultation window before 22 May 2026 to audit three things: whether existing clients can reach you without a long email thread, whether routine questions can be answered on the site itself, and whether you capture the trigger event cleanly, not just the enquiry. Each of those determines whether your practice is resourced for responsive advice.

A short pre-consultation website audit should cover:

1. Adviser pages. Does each adviser have a named biography with qualifications (e.g. Chartered Financial Planner CII or CISI, CII Level 4 Diploma in Regulated Financial Planning) and FCA Register number visible? Clients in a triggering moment need to know who they are speaking to.
2. Question coverage. Can a visitor find a plain-English answer to "what happens to my pension if my husband dies", "can I reduce my drawdown this year", or "what does it cost to move my ISA to you" without phoning the office?
3. Trigger capture. When a client raises an event, does the contact path record the context, or does it dump a generic "please call back" message into your inbox?
4. Response latency. Our piece on the 5-minute response rule for IFAs covers the data here: faster responses win more of the enquiries that turn up.
5. Consumer Duty traceability. Your Consumer Duty website obligations do not relax under CP26/10. They reinforce. Document what the website does and why.

This is not a theoretical exercise. The FCA's 2026 annual work programme has moved from "did you build the framework" to "show us the outcomes you are delivering," and the website sits inside that supervisory view.

Which website elements need updating first?

Start with three elements: the adviser biographies (so clients and prospects know who they are raising an issue with), the question-and-answer content that covers common trigger events, and the contact path itself. A contact form that surfaces an enquiry 24 hours later is not a responsive-advice tool. It is a compliance risk dressed up as marketing.

The annual model and the responsive model put different demands on a website. It helps to see them side by side.

Advisers who have already moved in this direction are using the site to do two things at once: answer routine questions without an adviser needing to pick up the phone, and route non-routine questions to the adviser with full context attached. That is what an AI chat widget trained on your own site content can do out of the box, and it is the backbone of what we cover in chatbot lead generation for IFA websites.

FAQ

When do the FCA annual review changes take effect?

The consultation closes on 22 May 2026. The FCA expects to publish a Policy Statement by the end of 2026. Any rule changes would then follow, typically after a further implementation window. Firms should not assume the current COBS 9A annual review obligations have gone away yet, because they have not. Use this period to prepare, not to pause.

Will advisers still be able to charge ongoing advice fees?

Yes. CP26/10 clarifies that firms may continue to charge for ongoing related services linked to an earlier personal recommendation, even where those services do not include a fresh suitability review every year. Charging remains tied to what the client agreed to receive. Existing FCA rules on evidencing delivery of the service still apply under Consumer Duty (PRIN 2A).

What is a periodic suitability assessment?

A periodic suitability assessment is a review of the continued appropriateness of a client's advice, conducted on a frequency the firm judges right for that client. Under MiFID II the current minimum frequency is annual, but CP26/10 proposes replacing that floor with a need-based approach. The outcome of each review must still be documented and communicated in writing to the client.

Does this change FCA Consumer Duty obligations?

No, it reinforces them. Consumer Duty still requires firms to deliver good outcomes and act in the client's best interests. What CP26/10 does is remove a prescriptive calendar rule and replace it with a flexible one that must be justified against the Duty. If anything, advisers will need stronger records of why a chosen review frequency is right for that specific client segment.

Do the FCA annual review changes apply to existing client agreements?

Existing written agreements with clients still govern what a firm has promised. If your ongoing service document commits to an annual review, that is what the client paid for. CP26/10 gives firms flexibility in the rule, but not in the contract. Any shift to periodic or needs-based reviews should be reflected in updated client-facing documents, not assumed by implication.

How does this interact with the FCA's targeted support regime?

The targeted support framework went live on 6 April 2026 and sits alongside, not inside, the advice rules in CP26/10. Our piece on FCA targeted support rules for IFA practices covers the overlap. The short version: targeted support serves non-advised consumers; CP26/10 reshapes how full advice services work for your existing clients.

What to do between now and 22 May

Draft your consultation response if you plan to submit one. Then look at your site with the responsive-advice lens. If an existing client wanted to raise a triggering event at 9pm on a Tuesday, could they do it from their phone, and would your practice have a record of it by the time you opened your laptop the next morning?

ChatIFA is an AI chat widget for UK IFA websites. It answers visitor questions using your own site content, captures the trigger event with full context, and emails you when a lead wants a conversation. The free tier is 25 messages a month with no payment details required. See chatifa.co.uk.