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The November 2025 Budget landed with far more weight for advisers than many expected. While the headlines focused on “growth” and “scale ups”, the detail told a different story. This Budget marks one of the most significant shifts in VCT and EIS design since the original risk-to-capital test. For advisers and paraplanners who use tax efficient investing strategically, the next few months will require some rethinking.

This week we are breaking down what has changed, why it matters, and how you can work through client conversations with clarity.

 

A crossroads for scale up capital

The Government has framed the Budget as a reset for the UK’s growth economy. The ambition is to funnel more private capital into established scale ups, rather than very early-stage companies. This shift appears in each measure, from tax relief changes to increased limits.

GrowthInvest‘s analysis highlights this clearly. While the Government talks about “unlocking investment”, the mechanisms lean toward channelling larger sums into later stage businesses, instead of motivating the riskiest start-ups.

GrowthInvest Analysis: UK “Scale up” Budget 2025 – VCT & EIS Changes

For advisers, this matters because many long-standing investment journeys have been built on early-stage exposure, tax planning efficiency, and diversification. Those levers may now work a little differently.

 

The big news: VCT income tax relief reduced

The most immediate change is the cut in VCT income tax relief, from 30% down to 20% as of April 2026. Although the percentage cut is less severe than some predicted, this is still the first real reduction in relief for two decades.

FI Group summarises the political aim well: widen access to VCT capital while reducing the cost to the Treasury.

VCT Relief Cut, VCT Limits Up: What Rachel Reeves Just Changed For Scale Ups

Two things stand out:

• The Government still sees VCTs as part of the national growth strategy.

• The balance has shifted toward higher investment caps rather than higher relief.

This opens the door for wealthier investors to contribute larger sums, but slightly weakens the incentive for smaller investors who have historically driven much of the market

 

Limits lifted across the board

Investment limits for both VCT and EIS have increased. For EIS and SEIS planning, this signals the same intent. Bigger tickets into slightly more mature businesses.

Invest How Now rounded this up clearly: higher limits, extended windows, and a stronger orientation toward funding businesses that are already scaling, not testing ideas.

UK Autumn Budget 2025: What EIS, SEIS and VCT changes mean for founders and angel investors

The Budget even speaks directly to founders and angels, reinforcing that the UK wants to sit closer to the US model of growth funding.

For advisers, this widens the client profile who may now consider VCT or EIS as part of a structured tax plan. It also raises suitability considerations around risk, timeframe, and diversification.

 

Industry reaction: a mix of optimism and unease

The VCTA’s statement captures the mood. The industry welcomes the commitment to the VCT model but expresses concern about the potential cooling effect of reduced relief on new investor inflows.

The VCTA releases a statement on the outcomes of the Autumn Budget

Their message is simple: stability matters. And while increased limits are helpful, tinkering with incentives risks slowing momentum at a time when scale ups still face funding gaps.

Advisers already know this tension. Tax planning is built on long term confidence. When rules shift, client hesitation follows.

 

So, what does this mean for advisers today?

Right now, three practical themes are emerging in conversations across our adviser network.

 

1. Revisit suitability tests for VCT and EIS

Risk-to-capital remains unchanged, but investment characteristics may drift slightly as funds tilt toward more established companies.

Consider revisiting:

• client risk appetite versus early-stage exposure

• diversification across managers and sectors

• liquidity expectations for clients nearing retirement

This is a good moment to update your research notes and ensure your documentation reflects the new landscape.

 

2. Adjust client conversations around relief

For some clients, the reduction in relief will not materially change appetite. For others, especially those who invested for the uplift rather than the growth opportunity, motivation may soften.

Client conversations may benefit from focusing on:

• the investment case rather than the relief

• the role of VCT and EIS within their wider tax strategy

• time horizons and exit expectations

The relief is still valuable. It is simply no longer the primary anchor.

 

3. Expect product design changes from providers

Managers will respond. We may see:

• more follow-on rounds

• more B2B and scale up focused portfolios

• new liquidity mechanisms

• additional investor education

Providers will now need to articulate their investment rationale more clearly. Keep an eye on mandate revisions in early 2026.

 

A wider trend toward “structured incentives”

Looking across the Budget, the direction of travel is clear. Reliefs and allowances are being reshaped to support larger, more stable companies earlier in their expansion path.

For advisers, this means suitability work becomes more important rather than less. When incentives shift, advice frameworks must be defended with clarity. This is particularly true for repeat investors with multi-year VCT or EIS histories.

 

Final thoughts

Change in tax efficient investing is nothing new. The sector evolves almost every two to three years. What matters now is how advisers help clients navigate the transition calmly.

The Budget did not remove incentives. It reframed them. The opportunity is still there for many clients, just with a slightly different entry point and a stronger emphasis on scale up exposure.

If this resonates with what you are seeing, we would love to hear from you. We are always happy to sense check a case or talk through research detail. No pitch, just people who work closely with these rules every day.

 

The Autumn Budget landed on Wednesday after several weeks of noise, leaks and confident predictions. While the final package was far smaller than the headlines suggested, it still introduces several changes that advisers and suitability consultants will need to build into their planning, suitability wording and client conversations.

These are not the sweeping reforms many expected, but they are meaningful. They affect tax planning, income projections and evidence requirements across a wide range of advice scenarios. My aim in this edition is to strip away the speculation and set out, in practical terms, what actually matters for your clients and your processes.

 

A Budget shaped by speculation, but still containing important changes

Much of the commentary on Wednesday centered on the gap between expectation and reality. The most dramatic rumours never appeared. Yet several mid tier changes will still influence suitability assessments, tax strategy and long term planning.

Advisers now need to help clients shift from a month of speculation to a clear understanding of what genuinely affects them. These changes are not seismic, but they will still require careful adjustments across the advice process.

 

The changes that matter and how they affect advice processes

Below is a structured overview of the confirmed measures most relevant to advisers and suitability consultants.

 

1. Cash ISA allowance increased to £12,000 for adults under 65

A targeted increase designed to improve tax efficiency for savers, particularly those who hold fragmented cash pots.

Actions:

⭐Update factfind templates

⭐Add a short line in suitability reports where relevant

⭐Consider consolidation of cash savings into wrappers

This is a useful adjustment, but not a system wide shift.

 

2. Salary sacrifice capped at £2,000 a year

Lighter than predicted, but still significant for clients who use enhanced or structured remuneration.

Actions:

• Identify clients currently above the limit

• Reassess pension funding strategies

• Update suitability wording

• Confirm whether employers intend to change scheme rules

Evidence the decision clearly in cases where sacrifice formed a meaningful part of the rationale.

 

3. VCT tax relief reduced from 30 percent to 20 percent

(Important change for tax planning and high net worth advice)

The tax incentive remains, but the reduced relief changes the balance of suitability for some clients.

Actions:

• Revisit existing VCT recommendations

• Adjust future recommendations and suitability rationale

• Update template wording around risk reward and tax efficiency

• Check capacity for loss discussions for clients near suitability boundaries

 

4. Business Relief: £1 million allowances now transferable on first death

This adds flexibility to estate planning strategies and strengthens the case for BR where objectives support it.

Actions:

• Update inheritance tax planning assumptions

• Add the new position to suitability reports where BR strategies are used

• Review joint planning cases involving BR qualifying assets

 

5. Dividend tax and property income tax rising by 2 percent

This affects business owners, landlords and clients with unwrapped portfolios.

Actions:

• Update cashflow models

• Review tax efficiency of dividend and rental income

• Consider repositioning assets into wrappers where appropriate

• Reflect the change in updated suitability wording

 

6. Routine annual adjustments

These include state pension increases, minimum wage changes and frozen tax thresholds. They are not headline announcements, but they matter.

Actions:

• Refresh planning assumptions

• Recheck clients near tax boundaries

• Prepare simple income summaries for clients who rely on predictable budgeting

 

What was expected but did not appear

Several widely predicted measures were absent, including:

• ISA system restructure

• Pension tax overhaul

• Inheritance tax reform

• Capital gains tax changes

For many firms, this stability is helpful. It avoids unnecessary rewrites and supports consistency in long term planning.

 

Supporting clear client conversations after Wednesday’s Budget

Many clients will have absorbed more speculation than fact. Advisers can reset expectations by keeping conversations simple and factual.

Helpful approaches:

• Provide a clear summary of confirmed changes only

• Explain that several predicted reforms did not happen

• Keep explanations straightforward and practical

• Invite clients to ask about anything they saw in the news

• Correct misinformation early to build trust

A calm, factual reset goes further than a technical breakdown this week.

 

What suitability consultants should prioritise

A concise checklist for suitability consultants and advice support teams:

Suitability wording:

• Update ISA, salary sacrifice, VCT, BR and dividend tax references

• Remove any pre Budget speculative assumptions

Templates and processes:

• Adjust ISA age banding

• Refresh VCT and BR language

• Update pension contribution and sacrifice logic

• Monitor provider commentary

Governance:

• Note all changes and rationale for audit clarity

 

Final reflections

Wednesday’s Budget may not have delivered the sweeping reforms many anticipated, but it still introduces meaningful changes that require adjustments across tax planning, suitability wording and advice strategy. These are mid tier reforms that matter, even if they did not dominate headlines.

If any part of the new measures leaves you unsure how it should be embedded into your advice process, feel free to get in touch. I am always happy to help you work through the detail.

Useful sources referenced:

BBC Budget live coverage: https://www.bbc.co.uk/news/live/cy8vz032qgpt

BBC analysis: https://www.bbc.co.uk/news/articles/cgmn991pz9jo

Independent live updates: https://www.independent.co.uk/news/uk/politics/budget-2025-rachel-reeves-isa-tax-live-updates-b2872397.html

IFS Initial Response: https://ifs.org.uk/articles/autumn-budget-2025-initial-response

Budget papers: https://www.gov.uk/government/collections/budget-2025

 

 

Estate planning has always been a blend of tax rules, family dynamics and adviser judgement. It is one of those areas where advisers often say, “it depends”, because the picture can shift quickly. This year, it feels like the picture is shifting faster than ever.

Upcoming changes to pensions, BR and APR reliefs, rule caps, and the impact of compounding on client estates over time are creating a new kind of challenge. Complexity is rising, planning windows are narrowing, and advisers are being asked bigger questions about intergenerational wealth.

The silver lining is that tech in our space is finally catching up. Tools that would have seemed ambitious not long ago can now model what really matters for clients, including long term estate projections and rule based triggers.

This month, I want to spotlight two things. First, the launch of a new IHT calculator created by TIME Investments. Second, a quick roundup of the latest adviser tech updates that caught our eye.

Let’s get into it.

 

A new IHT calculator that brings clarity to the chaos

TIME Investments have released a new IHT calculator that several of you have already asked about. You can try it here:

Inheritance Tax Calculator

It takes a client’s current estate and projects their future IHT position year by year up to 2040. It also builds in the upcoming rule changes across BR, APR and pensions. For advisers working with clients who are unsure how these moving parts interact, this kind of forward view can be invaluable.

Here are the client situations where this tool becomes particularly helpful:

• Clients with AIM BR investments, where BR drops to 50 percent in April 2026.
• Clients considering AIM BR for the first time. Even reduced relief can still drive meaningful impact.
• Households with TIME Advance or similar BR solutions, particularly where more than one million of BR may be invested.
• Clients relying on pension assets as part of estate planning, because pensions will start to be included in the estate from April 2027.
• Business or farm owners facing BR and APR relief caps from April 2026.
• Property heavy clients where house value growth drives long term IHT exposure.
• Blended estates involving pensions, BR assets, AIM shares, investments and cash.
• Families delaying decisions and needing a clear view of the cost of waiting.

For advisers, it has five practical benefits.

1. It simplifies complexity.
2. It saves time by producing a clean, downloadable client report.
3. It boosts client engagement in estate planning conversations.
4. It highlights planning opportunities at the right time.
5. It supports compliance with a transparent advice record.

With IHT receipts now at a record high of £7.5 billion, anything that helps clients understand their future position without overwhelming them is a welcome addition to the toolkit.

 

A quick look at what else is happening in adviser tech

The last month has been busy. Several providers have released updates worth keeping on your radar.

 

Quilter’s WealthSelect on Transact

This update strengthens the available MPS options on Transact and may help streamline discussions for advisers who want platform consistency without sacrificing choice.

 

ebi launches a fund of funds range

This addition will appeal to firms looking for simplified portfolio structures that still feel evidence based. Source:

ebi Portfolios launches Fund of Funds range

 

Dynamic Planner achieves an industry first

Dynamic Planner has earned AI certification, something that will reassure firms who want to use AI guided tools in a compliant, transparent way. Source:

Dynamic Planner achieves industry first AI certification

 

AdviserSoftware’s new comparison tool

This tool allows advisers to compare AI solutions with more clarity, something many firms have asked for as the market gets crowded. Source:

AdviserSoftware.com launches AI comparison tool for advisers

 

AJ Bell’s suite of adviser tools

AJ Bell has expanded its adviser toolkit, giving more options for cash flow, modelling and portfolio planning tasks. Source:

AJ Bell unveils suite of adviser tools

 

These updates point to a trend I think we will see more of. Adviser tech is no longer just about creating efficiencies, it is becoming a way to understand complexity and explain it simply.

That is exactly what clients value.

 

Looking ahead

The more rules shift, the more advisers will lean on tools that bring clarity without adding noise. What matters is not high tech for the sake of it, but tech that helps clients make informed decisions with confidence.

If this resonates with what you are seeing, I would love to hear from you.

 

This month has been a particularly active one for the FCA. Individually, none of the updates feel dramatic, but together they point clearly towards the direction of travel for 2025. As always, the FCA is focused on consistency, clarity, and consumer protection. For advisers and paraplanners, this is another reminder that evidence and governance matter just as much as the recommendation itself.

Below, I have summarised the key updates along with some practical reflections to help you keep your advice files strong and review ready.

 

**1. Consolidation in Advice and Wealth Management

Why the FCA is paying closer attention to scaling firms**

The FCA has released its review on consolidation in the advice and wealth management sector: https://www.fca.org.uk/news/news-stories/review-consolidation-financial-advice-and-wealth-management-sector

The trend is clear. More firms are being acquired, merged, or absorbed into larger groups. What concerns the FCA is whether those firms can maintain advice quality and control as they grow. Consumer Duty has made it obvious that process variability is no longer acceptable.

From an advice perspective, the biggest challenge sits in consistency. Different advisers across acquired firms often work with different templates, rationales, and approval checkpoints. That becomes a governance risk the moment firms start scaling.

My advice to teams is simple. Tighten your frameworks before the FCA tightens theirs. Review your templates, revisit your rationales, and ensure your records clearly evidence client objectives and suitability logic. Growth is positive, but only if the advice process grows with it.

**2. Crypto Exchange Traded Notes

 

A timely reminder on client categorisation**

The FCA has issued a fresh reminder around the rules for crypto ETNs, with a clear warning about inappropriate promotion: https://www.fca.org.uk/news/statements/information-firms-offer-crypto-exchange-traded-notes

Crypto ETNs remain high risk. The FCA has restated that firms must be strict in how they assess and evidence client categorisation.

For advisers and paraplanners, this is a good moment to revisit your segmentation notes. Many clients appear financially savvy but do not meet the bar for elective professional status. Suitability reports should clearly record the fact that these products were considered out of scope and why.

If your advisers receive crypto related questions, make sure they know the criteria for professional classification and where the lines are. Clear documentation protects both the client and the firm.

 

**3. Romance Scams

A reminder of why vulnerability evidence matters**

The FCA is urging banks to do more to prevent romance scams: https://www.fca.org.uk/news/press-releases/banks-need-to-help-break-spell-romance-scams

While this is a retail banking issue, it connects strongly to advice. Vulnerability can be subtle and situational. Clients who appear confident and independent on paper can still be at risk of manipulation.

From an advice quality perspective, this is a reminder to:

• Build vulnerability observations into annual reviews.  • Record behavioural changes in CRM notes.  • Make clients aware of your firm’s security protocols, especially around transfers.

Good vulnerability evidence is not about ticking boxes. It is about protecting clients in moments when they might not recognise a risk themselves.

 

**4. FCA Charges Three Finfluencers

What this means for advice firms who create content**

Three finfluencers have appeared in court after an FCA led crackdown on illegal promotions: https://www.fca.org.uk/news/press-releases/first-court-appearance-three-finfluencers-charged-fca-led-global-crackdown-illegal-promotions

Although most advice firms are not making TikTok content, this update is still relevant. It shows that the FCA is widening the scope of what counts as influence, and it expects anyone shaping financial decision making to follow financial promotion rules.

If your firm uses social media, webinars, newsletters, or YouTube, now is a good time to double check your content. Balance, risk warnings, and clarity on what is and is not advice need to be watertight.

For paraplanners who support content creation, remember that generic guidance must stay well away from personalised implications. A single loose phrase can change the nature of a post.

 

**5. FCA Opens Applications for Three Statutory Panels

A signal of more industry dialogue ahead**

The FCA is opening applications for three of its statutory panels: https://www.fca.org.uk/news/news-stories/fca-opens-applications-3-key-statutory-panels

This is a healthy development. It suggests the FCA wants a closer link with real adviser experience and technical insights from the industry.

If your firm has strong views on Consumer Duty, PI volatility, redress, or governance challenges, this is the moment to contribute via associations or directly through panel applications. The more practitioners involved, the more grounded the regulatory conversation becomes.

 

Final Thoughts

When you look at all of these updates together, the theme is easy to spot. The FCA wants stronger evidence, clearer logic, and better governance discipline across advice firms of all sizes. That aligns with what we see daily. Good advice is not just well written, it is well evidenced, well documented, and resilient under review.

If any of this reflects conversations you are having in your firm, we would be happy to talk it through.

 

You can’t open Professional Paraplanner this month without seeing the same headline: billions of pounds still sitting in savings accounts earning 1% or less.

It’s easy to understand why. After a decade of shocks – inflation, interest-rate jumps, and market whiplash – investors have grown cautious. But as we move towards 2026, that caution is quietly becoming costly.

 

The illusion of safety

Holding cash can feel like control. It’s visible, accessible, and seemingly “risk-free.” But when inflation averages 4%, £100,000 in a 1% savings account loses more than £9,000 of real value in three years. The line between prudence and erosion is thinner than most realise.

As advisers know, inaction is still a decision – one that can materially shape long-term outcomes.

 

Re-framing risk for clients

The challenge isn’t convincing clients to be brave; it’s helping them see that:

• Risk managed is not risk ignored. Diversification, time horizons, and product design all have structure and discipline behind them.
• Cash can be purposeful. Emergency funds are essential, but anything beyond that should serve a defined objective.
• Inflation is the silent loss. Use simple illustrations to make real-term erosion visible – it often changes the conversation faster than a market forecast ever could.
• Suitability is the anchor. Every portfolio decision should still be evidenced against the client’s objectives and appetite for loss.

 

Platforms and products expanding access

The industry is also adapting. HSBC’s Model Portfolio Service (MPS) is now live on Parmenion, Nucleus, and Novia, adding to an already broad list of platforms – from Aviva and Abrdn Wrap to Transact and 7IM. Greater accessibility means it’s becoming easier for advisers to offer risk-appropriate, diversified solutions without operational friction.

Similarly, Elston’s Smoothed MPS via Aviva highlights the shift toward products that keep clients invested while reducing volatility – a useful middle ground between fear and opportunity.

 

Why this matters now

When markets wobble, “safe” often feels like the right call. But from a suitability perspective, the adviser’s role is to bring balance – to turn emotional caution into structured confidence.

That’s where disciplined advice makes its mark: evidence-based recommendations, defensible rationale, and clear communication that bridges logic and reassurance.

Because safety, when left untested, isn’t really safety at all. It’s just deferred risk in another form.

If this reflects what you’re seeing in your client conversations, I’d love to hear how your firm is approaching it. No pitch – just a shared discussion on how we can keep advice grounded, balanced, and built to last.

 

 

The appeal never gets old

Few assets spark the same emotion as a classic car. For some, it’s the growl of a V12; for others, it’s the nostalgia of a Sunday drive with the roof down. But beyond the romance, classic cars are increasingly being discussed as serious investments – part collectible, part alternative asset class.

With demand for rare models and limited supply, the numbers have been impressive. According to Classic Car Clubs UK’s Q1 2025 Market Report, blue-chip classics like the Jaguar E-Type and Porsche 911 Turbo continue to hold value even in volatile markets. Yet, as advisers and paraplanners know, emotional assets can be tricky to quantify – and even trickier to justify in a diversified portfolio.

So, are collectible cars a legitimate long-term play, or just a beautifully polished gamble?

 

Understanding what drives the market

The Wealthspireanalysis ¹ breaks the investment case into three forces: scarcity, sentiment, and stewardship.

• Scarcity– production numbers are finite, and many vehicles are already lost to time.

• Sentiment– cultural cachet drives demand (think Bond-era Aston Martins or 80s Ferraris).

• Stewardship– the condition and provenance of the car determine its resale trajectory.

That last point is critical: these assets need constant care. A car that isn’t driven or maintained can depreciate faster than a bear-market portfolio.

 

The risk under the bonnet

The Credence Research ² and Goodsong Gallery ³ pieces agree; while headline returns can hit double digits, costs and liquidity risks are substantial.

• Maintenance & storage: Insurance, servicing, and climate-controlled storage can exceed 2–3% of value per year.

• Liquidity: Cars aren’t traded on an exchange – selling takes time, connections, and sometimes luck.

• Valuation volatility: Prices are often driven by auction trends, not fundamentals.

• Regulatory risk: Environmental legislation may tighten restrictions on older vehicles, impacting use and resale.

In other words, classic cars behave more like art than equities.

 

Portfolio fit: diversification or distraction?

According to Sierks Investors Magazine ⁴, the global collectible-car market is maturing. Institutions are beginning to index data on vintage-car performance, making it easier to model correlations with traditional assets. Early findings suggest low correlation with equities and bonds, which could make a small allocation (typically < 5%) a genuine diversifier – for the right client.

However, it’s not suitable for everyone. Advisers need to consider:

• Client objectives– is this wealth preservation, legacy planning, or lifestyle investing?

• Liquidity needs– will the client need to access capital quickly?

• Knowledge and engagement– does the client understand the market, or are they relying on third-party dealers?

As Luhhu Finance⁵ notes, successful collectors often treat their garages like businesses: meticulous records, regular valuations, and a clear sell strategy.

 

The UK scene in 2025

Market data from ClassicCarClubs.uk’s Q1 2025 analysis shows UK transactions slightly down in volume but up in average value – suggesting consolidation among serious collectors. Electric-vehicle policies have also boosted interest in “final-generation” petrol icons like the BMW M3 E92 and Audi R8 V10, listed by Auto Express ⁷ as among the “future classics”expected to appreciate over the next decade.

For high-net-worth clients, this isn’t just nostalgia – it’s a potential hedge against monetary inflation and currency fluctuation, albeit one best viewed through a long-term, discretionary-portfolio lens.

 

Practical takeaways for advisers

If a client raises classic cars in an investment meeting, consider framing the discussion around:

1. Purpose before product– clarify whether this is an emotional purchase or a portfolio allocation.

1. Full-cost view– include storage, insurance, and restoration in any ROI discussion.

1. Exit planning– how and when will value be realised, and through which channels?

1. Due diligence– verify provenance and authenticity; partner only with reputable auction houses or dealer networks.

1. Tax and reporting– remember that cars may not qualify for capital-gains exemptions and can complicate estate planning.

 

The bottom line

Classic cars can bring joy, status, and – in the right hands – returns. But they’re illiquid, maintenance-heavy, and sentiment-driven. As advisers, our role is to help clients balance passion with prudence, ensuring the thrill of ownership doesn’t override the discipline of investment.

If this resonates with what you’re seeing among your clients, we’d love to hear your perspective. Have you encountered more “alternative asset” conversations recently?

¹ Wealthspire: Investing in Collectible Cars (2025)

² Credence Research: Classic Cars as Investments (2024)

³ Goodsong Gallery: Are Classic Cars Still a Good Investment?

⁴ Sierks Magazine: Classic Cars as an Investment – Guide for Investors (2025)

⁵ Luhhu Blog: Why Investing in Vintage Cars Makes Financial Sense

⁷ Auto Express: Best Future Classics 2025

 

Retirement advice is having a moment. Between rising client expectations, looming tax changes, and the FCA’s sharper focus on Consumer Duty outcomes, suitability in retirement planning has never felt more scrutinised – or more complex.

Recent research from FT Adviser found that suitability reports remain a “constant choke” for advisers. The same message echoed across Professional Paraplanner’s autumn surveys: advisers are spending more time on report drafting than on client conversations, with pressure peaking around pension and decumulation cases.

The problem isn’t that advisers don’t know what to say.  It’s that the how– how to evidence rationale, balance flexibility and sustainability, and present recommendations in plain English – still feels too heavy for most workflows.

 

1. The Pension Pressure Cooker

Fidelity Adviser Solutions’ latest adviser research showed a marked rise in retirement income reviews this quarter, as clients seek to “get ahead” of potential Budget changes. That’s pushed paraplanning and suitability teams into overdrive – especially around drawdown sustainability and sequencing risk analysis.

Clients are understandably cautious. Many have seen markets recover since 2022 but remain wary of volatility and tax drag. Advisers, meanwhile, are wrestling with how to present complex pension logic clearly, without burying clients in detail or triggering rework at QA.

The bottleneck isn’t just technical. It’s structural. Most retirement advice still relies on sequential handovers between adviser, paraplanner, and reviewer – a process that was designed for regulatory safety but now hinders it. Every pass adds delay and dilutes accountability.

At We Complement, our suitability consultants are seeing that the fastest, cleanest outcomes come when logic is evidenced as it’s built. That means integrating fact-finding, objective validation, and product alignment before the report even hits a QA queue.

 

2. From Paraplanning to Proof

The industry’s language is shifting. “Suitability Consultant” isn’t just a new title – it’s a reflection of the role’s evolution.  Where a paraplanner traditionally constructed reports based on adviser input, a suitability consultant now tests and evidences the advice itself.

That proactive discipline changes everything:

• Errors are caught early, not patched later.

• Logic is consistent across advisers and files.

• QA becomes confirmation, not reconstruction.

As the FCA continues to assess Consumer Duty implementation, firms that can show advice integrity at the point of creation – not just in hindsight – are finding themselves on stronger ground.

It’s the difference between checking quality and proving suitability.

 

3. A Shift in Adviser Behaviour

The same Professional Paraplanner data found that over half of advisers are now “actively revisiting” retirement frameworks in anticipation of policy or tax change. But there’s a second driver: advisers want reassurance that their advice process is robust enough to withstand audit, even when circumstances shift.

In our own consulting work, we’re seeing three practical changes that make a difference:

1. Clearer objectives mapping. Linking every recommendation to a measurable client goal, not a generic outcome.
2. Version-controlled reasoning. Keeping an auditable record of every change – who made it, and why.
3. Embedded suitability scoring. Using structured frameworks (like our Suitability Matrix Score) to turn subjective “good” into objective evidence.

These are not just compliance niceties; they’re governance tools that de-risk advice teams and build confidence with both clients and regulators.

 

4. The Retirement Advice Balancing Act

Retirement advice has always been the ultimate test of judgement – balancing today’s client emotions with tomorrow’s unknowns.  But under Consumer Duty, that judgement must now be demonstrably reasonable. The regulator isn’t just asking whether a client’s plan makes sense; it’s asking whether the processthat produced it is reliable, repeatable, and aligned to FCA rules.

That means suitability isn’t a one-off test; it’s a continuous discipline.

• COBS 9.2.1R requires firms to ensure suitability of recommendations.

• SYSC 3.2.6R demands that systems themselves prevent foreseeable harm.

• Consumer Duty Outcome 1 obliges firms to prove good client outcomes, not just intend them.

In practice, those three lines converge in a simple principle: advice should stand up the first time.

 

5. Looking Ahead

With the Autumn Budget approaching and client nerves heightened, advisers face another surge in last-minute pension reviews. The firms that thrive through it will be the ones that treat suitability as a live process, not an end-stage hurdle.

We Complement’s view is that the answer lies in Advice Integrity – embedding evidence and alignment from the first client conversation through to final file.  When suitability becomes part of the advice build, retirement planning stops being a choke point and starts being a confidence point.

 

Final Thought

Retirement advice will always be complex. But complexity doesn’t have to mean opacity.  The firms that simplify the path – for advisers, for clients, and for auditors – are the ones that will win both trust and time.

If this resonates with what you’re seeing in your own firm, we’d love to hear from you.  No pitch. Just a conversation between people who care about getting advice right.

 

Why “intelligible pensions” is the tech question of our time

Ask any adviser or paraplanner what’s hardest to explain, and pensions will be near the top of the list. Between legacy schemes, tax quirks, retirement choices and regulation, even a “plain English” summary can sound like a puzzle.

So when I saw the headline “Could AI be the answer to making pensions intelligible for all?”– I stopped scrolling. Because if there’s one part of advice crying out for clarity, it’s pensions.

This month’s TechTalk takes that question and pairs it with three big tech moves in our sector – to explore how AI might finally help advice make senseto everyone.

 

1 | “Intelligible” isn’t simple – it’s structural

A recent Professional Adviser article hit the nail on the head: pension language isn’t confusing by accident. It’s confusing because the system itself is complex. AI can’t magic that away – but it canact as a translator between the system and the saver.

In practice, that could mean:

• Explaining scheme rules or benefits in plain, personal terms

• Letting users ask questions in their own words (and get answers that build confidence)

• Tailoring explanations to different literacy or knowledge levels

• Spotting when someone’s lost, and suggesting when to bring a human into the loop

We’re already seeing early versions of this – “pension specialist” chatbots that can interpret scheme documents and respond conversationally. It’s promising, but as always, the line between simplification and distortion is thin. Accuracy, oversight, and context are everything.

 

2 | AI is moving from experiment to infrastructure

If you look at what’s happening across financial services, the pattern is clear – AI isn’t just a novelty anymore. It’s being built into the backbone of how firms work.

• Legal & General × Microsoft are using AI to enhance client interactions and anticipate needs.

• AJ Bell + Dynamic Planner have integrated to remove manual handoffs – the groundwork AI depends on.

• Nucleus / Third Financial + Titan Wealth are taking it further with platform-as-a-service flexibility, giving firms room to plug in AI tools of their own.

The message? These aren’t pilot projects anymore. They’re early signs of AI becoming part of the advice architecture– less about shiny new tools, more about smoother, smarter systems.

 

3 | Where AI is already proving useful

A few real-world examples show where AI is already earning its place:

But let’s not gloss over the caveats – hallucinations, data privacy, and regulatory limits still need careful handling. Used well, AI could raise standards. Used badly, it risks confusion at scale.

 

4 | Four questions to ask before you jump in

If you’re thinking about introducing AI to improve clarity, start by asking:

1️⃣ Where are clients getting stuck? Is it in benefit summaries, decumulation options, or tax explanations? Start where misunderstanding costs the most time.

2️⃣ Do your systems talk to each other? AI is only as smart as the data it can reach. If your tools aren’t connected, your AI will be guessing in the dark.

3️⃣ What’s your “human handover” rule? Decide early when a person should step in – and make sure that’s logged, not left to chance.

4️⃣ How will you measure understanding? Track feedback, rewording requests, and drop-off points. They’re gold dust for continuous improvement.

AI should assistadvice, not automate it. The moment clients feel “talked at” instead of “spoken with,” we’ve missed the point.

 

5 | The regulatory line is still forming

Right now, there’s a healthy debate about whether AI explanations could ever count as “advice.” The FCA’s watching closely – especially as the 2026 pensions dashboards start taking shape.

Experts are already urging boards to build AI governance policies: define your scope, set guardrails, and make sure accountability stays human. The PLSAhas echoed that message – cautious optimism, yes, but oversight must stay front and centre.

 

Final thoughts: yes – but only if we build it well

So, could AI make pensions intelligible for all? Yes – if we let it translate, not replace.

AI won’t remove complexity, but it can help bridge the gap between technical language and human understanding. Done right, it can make advice land– turning jargon into clarity, curiosity into confidence.

The real test isn’t whether AI can talk. It’s whether clients trust what it says.

If that’s the challenge your firm’s exploring, we’d love to hear how you’re approaching it – no pitch, just a shared curiosity about doing advice better.

 

This month, the FCA reminded us – again, that proving compliance isn’t enough. It’s not about showing you followed a process; it’s about showing the process worked.

From pension lump sum cancellations to behavioural decision making in investment advice, the regulator’s latest activity is pointing to one clear direction: firms must be able to evidence good outcomes, not just intend them.

In this edition, I’ve summarised the key regulatory movements and what they mean for firms building advice that’s both compliant and defensible.

 

1. Pension Lump Sums: Clarity Over Convenience

The FCA’s latest statement on tax-free pension lump sums underlines how clarity and timing of communication remain under scrutiny.

Clients must be told, clearly and early, about their cancellation rights when accessing tax-free pension cash. This might sound procedural, but it cuts to the core of Consumer Duty – ensuring clients can make informed decisions, not just sign compliant paperwork.

If your firm uses templated pension communications or scripted processes, it’s worth reviewing:

• When and how cancellation rights are explained.
• Whether the language used matches the client’s understanding.
• How that understanding is evidenced in the file.

Because in 2025, intent isn’t enough – evidence is everything.

 

2. CP25/17: Behavioural Oversight Is the Next Frontier

The FCA’s Consultation Paper CP25/17 signals a growing focus on the behavioural side of consumer decision-making.

The consultation explores how firms present information, the sequencing of options, and the role of framing in client understanding. It’s another sign that “clear, fair, and not misleading” is evolving into “clear, understood, and evidenced.”

This shift has practical implications:

• Advice documentation should show how recommendations were presented and interpreted – not just the technical justification.
• Internal reviews need to track behavioural indicators such as overrides, deferrals, or drift from client objectives.
• Governance frameworks must demonstrate that behavioural risks are actively managed, not assumed away.

In other words, Consumer Duty has moved from paperwork to psychology.

 

3. The Bigger Picture: Governance and Accountability

According to Grant Thornton’s weekly regulatory insight, the FCA’s ongoing communications this quarter consistently tie back to governance evidence.

Boards are being encouraged, or required, to demonstrate how senior management systems (SYSC) translate into real-time oversight. Under SM&CR, defensible delegation depends on showing that advice risk is identified, monitored, and resolved – not just that a policy exists.

We’re seeing many firms move from static QA to what we call active assurance: live suitability scoring, override analysis, and version-controlled logic. It’s the difference between being compliant on paper and being confident under audit.

 

4. Suitability: Still the Linchpin

Every regulatory thread – Consumer Duty, PROD, SYSC, or COBS – eventually comes back to suitability. But suitability today is less about justification and more about defensibility.

As we explored in our recent Advice Integrity white paper, the question isn’t “Can you show why this advice was suitable?” It’s “Can you prove it was suitable the first time?”

That mindset shift requires:

• Structured, versioned advice logic.
• Measurable evidence of client understanding.
• Integrated adviser–consultant collaboration before QA even begins.

At We Complement, our Suitability Consultants are already embedding these frameworks – ensuring firms aren’t just compliant, but audit-ready by design.

 

5. Practical Takeaways for October

If you’re reviewing internal processes this month, here are three simple but high-impact checks:

1. Audit your pension communications. Are cancellation rights clear, accurate, and captured as evidence of understanding?
2. Test a recent advice file under Consumer Duty lens. Would a third party conclude the client’s decision-making was genuinely informed?
3. Review your management information (MI). Are you tracking behavioural indicators – such as override rates or objective drift – in a way that feeds back into governance learning?

These aren’t tick-box tasks; they’re the mechanics of modern integrity.

 

6. Why This Matters

The FCA’s narrative has become unmistakable: process without proof is no longer protection.

Good governance isn’t reactive; it’s built in. The firms that thrive under this evolving regime will be those that move from “checking” to “evidencing.”

As advisers, paraplanners, and suitability consultants, our collective role is to make that evidence feel natural – embedded, not bolted on.

That’s how trust is rebuilt. That’s how integrity becomes the norm.

 

If this resonates with what you’re seeing in your firm, we’d love to hear from you. No pitch – just people who get financial advice, trying to make sense of what the FCA really means by “good outcomes.”

 

War, Energy, and the New Fragility in Supply Chains

This summer has been a reminder of how fragile the global investment environment remains. Conflict and instability in Eastern Europe and the Middle East continue to ripple into energy prices, and the knock-on effect for UK investors is real.

The challenge for advisers is balancing client portfolios against this backdrop of energy vulnerability and disrupted supply chains. For many, the lesson is diversification: resilience doesn’t come from betting on a single sector, but from blending exposures across asset classes and geographies.

Professional Paraplanner recently underlined this point – fragility isn’t going away, so portfolios must be designed to flex with events rather than try to predict them.

 

High Turnover Strategies – A Contrarian Defence?

Another theme sparking debate is the value (or risk) of high turnover strategies. The conventional wisdom is to minimise churn to keep costs and tax drag low. But some managers argue that in volatile conditions, an active, nimble approach can add value.

The question advisers need to ask: is this discipline or reaction? Turnover in itself isn’t a strategy – it must be paired with a clear rationale, whether it’s capturing opportunities in shifting markets or mitigating downside risk. As ever, transparency on cost and risk to clients is the priority.

 

TIME:Advance – A Case Study in Investor Confidence

One of the standout updates this quarter has been from TIME:Advance, which continues to set itself apart in the Business Relief (BR) market.

• Top independent rating retained – Martin Churchill’s 2025 report again placed TIME:Advance as the most highly rated BR provider, noting their avoidance of leverage in renewables and their external valuations via BDO.
• £1.5bn AUM milestone – Assets under management have surged 50% since 2023, underlining both investor demand and confidence in the proposition.
• Rights Issue top-up window – Existing investors can still participate until 17 October (with cheques due by the 15th). Importantly, shares are backdated to the original investment date, which could qualify immediately for BR relief.
• Structured CPD webinars – Their “When BR…” series has attracted over 1,000 sign-ups, reflecting adviser appetite for practical CPD.

Behind these milestones sits a wider story: HMRC’s IHT receipts are soaring. In just the first five months of 2025/26, collections hit £3.7bn, up 5% year on year. Forecasts suggest receipts could exceed £9bn this year and £14bn by 2029–30. Frozen thresholds and rising asset values mean the pressure is only increasing.

For advisers, the question is less about if clients are exposed to IHT, and more about how quickly the exposure is growing.

Market Movers

It’s not just inheritance tax shaping the landscape. UK retail investors withdrew £1.8bn from funds in August, a sixfold increase from the prior month. Whether this is tactical repositioning or deeper nervousness remains to be seen – but it reinforces the need for advisers to keep client communication clear, frequent, and evidence-based.

 

Practical Takeaways for Advisers

• Stress test diversification: Portfolios should be designed to withstand energy price shocks and supply chain volatility, not just short-term market dips.
• Interrogate turnover strategies: Ensure the rationale is clear and the cost/benefit transparent for clients.
• Engage with IHT planning early: Rising receipts are a wake-up call – Business Relief and estate planning solutions remain essential tools.
• Stay close to clients: With retail flows showing volatility, proactive communication is critical to client trust.

Final Word

At We Complement, our role isn’t to tell advisers what to recommend, but to help them frame advice that’s evidence-based, defensible, and clear for clients. Whether it’s BR planning, portfolio structuring, or suitability oversight, the goal is the same: advice that holds up in real life, not just on paper.

If this resonates with what you’re seeing, we’d love to hear from you.

– Paul