The annual review is going. The FCA says technology can help decide when.
3.7mclients pay for the review the FCA proposes to replace
80in every 100 pounds of adviser-charge revenue come from ongoing services.83in every 100 reviews were delivered, across 22 large firms.48in every 100 small firms use or are considering AI in advice. Among large firms, 95.
Has this person’s life changed enough to need an adviser?
- Under the annual rule, the calendar answered
- The date goes
- A trigger decides, increasingly a model
- Who notices?
Under the proposed rule, the firm answers that question for every client, every year.
CP26/10 takes away the date, and changes one word.
The requirement to consider “necessary” information becomes an expectation to consider “sufficient” information.
The review is what advised clients pay for.
Two of the largest advice businesses report provisions still open for reviews they could not evidence.
Something now has to notice when a client’s life has changed.
Find out what would trigger your next client review.
- ReadSixteen pages, including seven things that can be done now, none needing new law.Download the PDF
- TalkOne conversation about your own firm, and whether the question applies to it.Book a meeting
- TestSix to eight weeks: a readiness assessment, use case triage and a regulatory and legal position paper.How it works
Every vendor claim met in the research is excluded on the record, with an AI advice failure rate, claims-management refund figures and a government figure quoted by the FCA, because its underlying survey could not be read. Verified at 24 September 2026.
What’s in the briefing
What’s inside the sixteen pages
Written for an executive who knows the sector well and AI not at all:
- A note on the numbers: what is included, what was excluded and why
- A trillion pounds under advice, and a workforce that has not grown
- The pressure point: advice reaches fewer than one adult in ten
- The review loses its date, and the fact-find loses a word
- Four risks specific to advice, none of them about the technology working
- What the record shows: reviews delivered, and what unevidenced ones cost
- The threat side: the unregulated adviser already in the client’s pocket
- The UK legal position, and the change from “necessary” to “sufficient”
- Beyond the UK: the European supervisor’s AI statement for advice
- Seven things that can be done now, none needing new law
- Three levels defined by where accountability sits, and three horizons
- An eight-workstream way in
Questions people ask before reading
Is this vendor material?
No. Every figure traces to the FCA, the Financial Ombudsman Service, the European Securities and Markets Authority, UK Finance’s own data collection, the statute book, or a firm speaking on its own published record. No vendor source appears anywhere in it.
Is it free to download?
Yes. It downloads directly, with no form and no email address required.
Does it cover targeted support?
Only in passing. Targeted support at the point of pension access is outside the scope of this briefing.
Is the briefing critical of the firms it names?
No. Firms appear only through figures each has published in its own results. The briefing draws no conclusion about either beyond what the firm itself has published.
How current is the research?
Verified against primary sources as at 24 September 2026, including CP26/10 (25 March 2026), the FCA’s advice firms survey (23 April 2026) and wealth management survey (18 August 2026, on data to the end of 2024), and firms’ 2025 results. No policy statement following CP26/10 had been published at that date.
What if I want to take this further?
The briefing ends with an eight-workstream action plan. The first three, readiness assessment, use case triage and a regulatory and legal position paper, form a natural first engagement of six to eight weeks, which fits before the policy statement expected in Q4 2026.