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Inside Suitability When cyber stops being an IT issue and starts showing up in advice work

By
Amy North

News

Cyber security has become one of those topics that firms know matters, but are often pulled into thinking about reactively rather than proactively.

It has not crept into the advice world quietly. It has arrived through governance, outsourcing, and accountability. And whether advisers like it or not, it now sits firmly in the regulatory spotlight.

Recent industry coverage suggests many firms are still underestimating how exposed they are. Money Marketing recently warned that regulators are increasingly concerned about a lack of focus on cybersecurity across advice firms, particularly where third parties are involved.

Advice firms’ lack of focus on cybersecurity is ‘worrying’

That concern is not abstract. It is already shaping the questions firms are being asked.

 

Why this feels different to before

For a long time, cyber security sat somewhere between IT support and platform providers. Many firms trusted that the right things were happening in the background, without needing to look too closely.

What has changed is not the threat itself. It is the expectation.

Under SYSC and Consumer Duty, firms remain responsible for client data and outcomes, even when work is outsourced. That responsibility cannot be passed down the chain.

FT Adviser has highlighted this shift repeatedly. Recent coverage shows firms being challenged less on whether they have policies, and more on whether they can evidence real, working controls.

Adviser technology launch first step to ‘rethink investment process’

Another piece points to cyber resilience becoming part of day-to-day governance, rather than something reviewed once a year. https://www.ftadviser.com/content/8fef799a-8fee-4fc0-9ac8-42cefeed9313

That is why this feels heavier than before. It is no longer a distant or technical issue.

 

Outsourcing does not reduce scrutiny

Most advice firms rely on third parties. Platforms, CRMs, cloud storage, research tools, paraplanning, and suitability support.

Each relationship introduces risk, even when it works well.

Regulatory guidance on outsourcing and operational resilience is clear that firms must understand how those risks are managed. The Bank of England’s CBEST framework reinforces this focus on real-world resilience rather than paper plans.

CBEST Threat Intelligence-Led Assessments

In practice, what often causes difficulty is not a lack of care, but a lack of evidence. Many firms trust their suppliers. Far fewer can clearly show how that trust is assessed, reviewed, and recorded.

 

What firms are really being judged on

From the conversations happening across the profession, regulators and insurers are not looking for perfection. They are looking for confidence and consistency.

They want firms to be able to explain, calmly and clearly:

  • where client data sits
  • how cyber risks are identified and owned
  • how third-party providers are assessed and monitored
  • what would happen if something went wrong

This is why independent assurance frameworks are getting more attention. They provide a shared reference point for firms, regulators, and insurers alike.

EIOPA’s work on the Digital Operational Resilience Act shows that this thinking extends well beyond UK advice firms.

Weekend Essay: Beware, the cyber hackers are coming

And commentary like this Money Marketing weekend essay is a useful reminder that cyber risk is not theoretical, or going away. https://www.moneymarketing.co.uk/opinion/weekend-essay-beware-the-cyber-hackers-are-coming/

 

A few questions worth asking internally

For many firms, the challenge is not willingness. It is knowing what good looks like in practice.

A few questions that often help bring clarity:

  • Do we know exactly where our client data lives?
  • Could we confidently explain our cyber controls to a regulator or insurer?
  • Do we review supplier security regularly, or only at onboarding?
  • If an incident happened tomorrow, would roles and responses be clear?

These are governance questions, not technical ones.

 

Where standards like ISO 27001 fit

Frameworks such as ISO 27001 are appearing more often in regulatory and due diligence conversations because they force structure.

They require risks to be identified, controls to be documented, and reviews to happen on an ongoing basis. For many firms, that helps remove subjectivity from conversations about cyber and data security.

That does not mean every advice firm needs certification. It does mean firms need a credible way to demonstrate control, rather than rely on assumptions.

Often, it is less about the standard itself, and more about being able to answer questions with confidence when they arise.

 

A final thought

Cyber resilience might not feel connected to day-to-day advice, but when data integrity fails, trust fails. And trust underpins everything advisers do.

Firms that take time now to understand their exposure, tighten oversight, and document decisions will be far better placed as scrutiny continues to increase.

If nothing else, this is a good moment to pause and ask whether you would feel comfortable evidencing your position, not just explaining it.

If you are already having those conversations internally, you are not behind. You are very much in step with where the profession is heading.

 

If you’ve been scanning the regulatory horizon lately, you’d be forgiven for thinking it’s been a bit quiet. No big consultations. No sweeping policy rewrites. No dramatic U-turns.

But quiet months often matter the most.

Because when you put the recent FCA updates side by side, and layer in what we’re seeing from FOS decisions, a clear theme emerges. The regulator’s focus is narrowing. Less noise. More intent. And a growing expectation that firms can evidence good advice, not just talk about it.

Here’s what’s caught our eye this month, and why it’s worth paying attention.

 

Cash ISAs: a policy idea that says a lot

The government’s proposal to slash the cash ISA allowance has been widely reported, and just as widely criticised. The idea, in short, is to push savers out of cash and into investments to support long-term growth.

Professional Paraplanner covered it well here:

Government doubles down on plans to slash cash ISA allowance

Whether or not this policy ever lands, the direction of travel matters. There is a clear and ongoing frustration at a policy level about the UK’s love affair with cash, and the perceived drag this creates on both individual outcomes and the wider economy.

For advisers and paraplanners, this isn’t about reacting tactically. It’s about being ready for the conversation.

Clients holding large cash balances often aren’t being irrational. They’re responding to uncertainty, poor past experiences, or a lack of confidence in markets. If policy pressure ramps up, those client conversations will become more frequent, and potentially more charged.

The takeaway here is simple. Firms that can clearly evidence why cash is appropriate, or not, for a given client will be far more comfortable navigating what comes next.

 

Mortgages, first-time buyers, and a widening advice gap

The FCA’s latest mortgage proposals focus on improving access for first-time buyers and the self-employed. Again, not headline grabbing, but quietly significant.

Professional Paraplanner’s summary is here:

FCA unveils mortgage plans to support first-time buyers and self-employed

What stands out is the regulator’s ongoing concern about people falling through the cracks. Those with non-standard incomes. Those priced out by rigid affordability models. Those who need advice the most, but struggle to access it.

This theme mirrors what we see elsewhere in regulation. The FCA is less interested in whether firms follow processes for their own sake, and more interested in whether outcomes make sense for real people with messy lives.

For advice firms, this reinforces the importance of joined-up thinking. Mortgage advice, protection, investments, pensions. They are not separate silos in the eyes of the client, or increasingly, the regulator.

 

“Millions to get more help” – and higher expectations with it

The FCA’s announcement that millions more people will receive help with investment and pension decisions sounds positive, and it is.

You can read the press release here:

Millions of people set to get extra help with investments and pensions decisions

But there’s a flip side.

More help means more scrutiny of how that help is delivered. Especially where guidance, support tools, and advice sit close together. The boundary issues haven’t gone away. If anything, they’ve become more important.

Firms offering streamlined services, annual reviews, or ongoing advice need to be crystal clear about what is being delivered, how often, and how it is evidenced.

Which brings us neatly to pensions.

 

Pension value under the spotlight

Another FCA release this month puts pension value firmly back on the agenda. Not just charges, but outcomes.

Pension value to be put under the spotlight

Value for money is no longer a vague concept. The expectation is moving towards demonstrable assessment. What is the client paying. What are they getting. And how do you know it remains appropriate.

Annual reviews play a central role here. Which makes recent FOS decisions particularly relevant.

 

A FOS reminder: if you can’t prove it, it didn’t happen

With regulatory updates thin on the ground, we’ve been keeping an eye on FOS decisions for practical insight. One recent case, DRN-5790176, is worth a read for anyone involved in arranging or documenting annual reviews.

In short, the client complained that they had not received the annual reviews they were paying for, and that their portfolio was unsuitable for a growth objective.

The adviser argued that reviews hadn’t taken place because the client was difficult to contact and had declined meetings. FOS accepted this might be true, but there was a fatal flaw. There was no evidence.

No emails. No call logs. No meeting invitations.

As far as FOS was concerned, if you can’t prove it, it didn’t happen. The outcome was a refund of ongoing advice charges, plus 8 percent simple interest per year.

Interestingly, other parts of the complaint were rejected. The adviser could evidence that attitude to risk had been revisited during reviews that did take place, and that portfolio composition had been clearly explained using review documentation and visuals.

Same client. Same firm. Different outcomes. All down to evidence.

 

What this all adds up to

Across policy proposals, FCA announcements, and FOS decisions, the message is consistent.

The regulator is less interested in intent, and far more interested in proof.

For firms, a few practical reflections are worth considering:

·  Are annual reviews clearly defined, scheduled, and evidenced?

· Can you demonstrate attempts to engage clients, even when they disengage?

·  Is your documentation good enough to stand alone, months or years later?

·  Do your records tell the story without needing explanation?

These aren’t theoretical questions. They’re operational ones.

If this resonates with what you’re seeing in your firm, we’d love to hear from you. No pitch. Just people who spend a lot of time thinking about how advice stands up when it really matters.

 

Orphan drugs, biotech, and the reality behind the investment headlines

Biotech is back in the headlines again. UK investment ticking up. Life sciences described as a strategic growth engine. A renewed focus on rare diseases and orphan drugs.

For advisers, this tends to land in two ways.

Some clients see the innovation story and ask whether this is “the next big thing”. Others already hold biotech exposure and want reassurance after a volatile few years.

As ever, the reality sits somewhere in the middle. There is genuine long-term potential here, but it is not simple, quick, or risk free. This week, I want to unpack what is actually driving the orphan drugs space, what that means for biotech investment more broadly, and how advisers can frame sensible conversations with clients.

 

What are orphan drugs, and why are they getting attention?

Orphan drugs are treatments developed for rare diseases, typically conditions affecting fewer than 5 in 10,000 people in the UK or EU.

Historically, these diseases were underfunded and underserved. Development costs were high, patient numbers were low, and commercial incentives were weak.

That has changed.

Governments and regulators now actively encourage orphan drug development through incentives such as:

  • Market exclusivity for approved treatments
  • Tax credits and grants
  • Faster regulatory pathways

The UK Parliament’s briefing on rare diseases highlights how these incentives are designed to stimulate innovation while addressing unmet medical need. It is worth a read for context rather than detail.

From an investment perspective, this matters because orphan drugs can offer high margins, strong pricing power, and long exclusivity periods once approved.

 

The UK biotech investment picture, steadier than the headlines suggest

After a tough couple of years for biotech globally, recent data suggests UK investment is stabilising rather than surging.

Pharmaphorum reports that UK biotech investment ticked up in Q2, with industry bodies describing conditions as “holding firm”  rather than booming.

That distinction is important.

This is not a hype-driven recovery. It is a selective, cautious return of capital, often focused on later-stage companies, proven pipelines, and areas like rare diseases where regulatory support is clearer.

For advisers, that supports a more measured narrative. This is not about timing a bounce. It is about understanding where capital is being deployed and why.

 

Intellectual property is the real value driver

One thing that often gets missed in client conversations is that biotech investing is not just about science. It is about intellectual property (IP).

Strong patents and defensible IP are what turn research into investable assets. Without them, even successful treatments struggle to deliver long-term shareholder value.

The ABPI and Kilburn & Strode both highlight how IP strategy underpins innovation, funding, and eventual commercial success in life sciences.

In practical terms, this means:

  • Early-stage biotech is highly binary. Success or failure can hinge on a single patent or trial outcome.
  • Larger, diversified biotech firms tend to manage this risk better through broader pipelines and layered IP protection.

This is often where adviser judgement really matters, helping clients distinguish between innovation exposure and speculation.

 

The long game, not a quick win

Several commentators, including Janus Henderson, frame biotech as a long-cycle investment. One that requires patience, diversification, and realistic expectations.

That aligns closely with what we see when reviewing portfolios and recommendations.

Biotech, including orphan drug exposure, can play a role within a wider growth allocation. It rarely makes sense as a concentrated bet for most retail clients.

Useful framing questions for advisers might include:

  • Is this exposure aligned with the client’s capacity for loss, not just their attitude to risk?
  • Is the investment diversified across companies, regions, and development stages?
  • Are time horizons genuinely long enough to ride out regulatory and clinical setbacks?

 

Practical takeaways for advisers

If biotech and orphan drugs are coming up more often in client conversations, a few grounding points can help keep advice balanced and defensible.

  • Focus on themes, not stock picking. Funds and diversified vehicles reduce single-trial risk.
  • Anchor discussions in outcomes, not innovation headlines. Clients care about returns, volatility, and fit with their plan.
  • Be clear about uncertainty. Regulatory support helps, but it does not remove development risk.
  • Document rationale carefully. Especially where higher-risk growth assets sit alongside core planning objectives.

For accessible overviews that clients may already be reading, these pieces give a reasonable starting point.

Investing in Biotech: Top UK Biotech Stocks of 2026

Should you invest in biotech?

 

Final thoughts

The renewed focus on orphan drugs reflects something positive. Innovation is being directed at real, unmet needs, and the UK remains an important part of that ecosystem.

From an advice perspective, the opportunity is not about chasing the story. It is about translating a complex, specialist area into clear, proportionate investment decisions that genuinely serve the client’s long-term plan.

If this resonates with what you are seeing in client conversations, we would love to hear your perspective. And if you want to talk through how these themes are showing up in real cases, just reach out. No pitch, just people who get financial advice.

 

 

Technology is speeding up. Advice still needs people.

There’s no shortage of commentary right now about where advice technology is heading.

AI tools are becoming more capable. Platforms are evolving quickly. Providers are talking about automation, integration, and efficiency as we move towards 2026 and beyond.

On paper, it all sounds promising.

But when you speak to advisers and paraplanners, what we refer to as Suitability Consultants, day to day, the conversation is a little more grounded. Less about what technology could do, and more about what it actually helps within real advice scenarios.

That gap between potential and practice is where most firms are currently operating.

 

What the recent tech conversation is really about

A few recent pieces have captured this tension well.

FT Adviser has explored how AI is being introduced across advice firms, particularly in areas like research support, documentation, and process efficiency. There’s a clear appetite to reduce admin pressure and free up adviser time, especially as capacity remains stretched. https://www.ftadviser.com/content/e0567ef2-002d-4599-abe5-c3fe7aa9b459

At the same time, there’s a recognition that AI is not a silver bullet. Another FT Adviser piece highlights the risks of over-relying on automated outputs without sufficient oversight, particularly where judgement, nuance, and client context matter. https://www.ftadviser.com/content/8eeab3d6-5109-4ecc-938d-f4b84d72c143

Professional Adviser has also weighed in, questioning whether the next wave of platform and tech change represents a genuine opportunity for advisers, or simply another layer to manage if processes are not fit for purpose first. https://www.professionaladviser.com/opinion/4523768/platforms-2026-bad-opportunity

Anthony Rafferty makes a similar point in his recent commentary. Technology only works when it supports clear processes and good decision making, rather than trying to fix structural issues after the fact. https://www.professionaladviser.com/opinion/4523731/anthony-rafferty-adviser-tech-fixes-processes-fit-purpose-2026

Taken together, the message is fairly consistent.

Technology can help, but only when it is built around how advice actually works.

 

Where AI genuinely helps in advice firms

Used well, AI can be a useful support layer.

We’re seeing firms use it effectively for things like:

  • Helping summarise large volumes of information
  • Supporting initial research and comparisons
  • Spotting gaps or inconsistencies in data
  • Reducing time spent on repetitive administrative tasks

All of this can create breathing space, which most firms welcome.

But it works best when it sits alongside experienced Suitability Consultants who understand advice, regulation, and client nuance.

AI can surface information. It cannot judge suitability in context.  It can draft text. It cannot sense-check intent.  It can flag patterns. It cannot challenge an adviser’s thinking when something does not quite sit right.

That distinction matters.

 

Why Suitability Consultants are still central, not optional

One thing we feel strongly about is that technology will never replace the role Suitability Consultants play, often known more widely as paraplanners, as a sounding board for advisers.

Being able to pick up the phone, talk through a complex case, or sanity-check a recommendation is not something software can replicate.

Suitability Consultants add value in the moments that matter most, for example:

  • When a case sits outside the usual parameters
  • When client objectives are unclear or conflicting
  • When suitability hinges on judgement rather than rules
  • When an adviser needs to talk through the “why”, not just the “what”

Those conversations are often where risks are spotted early and better outcomes are shaped.

Technology can support that process, but it should never replace it.

 

A practical lens firms can apply now

If you are reviewing technology in your firm, or being asked to adopt new tools, a few simple questions can help cut through the noise.

Before implementing anything new, ask:

  • What part of the advice process is this actually improving
  • Does it reduce friction, or just move it somewhere else
  • Who is responsible for sense-checking the output
  • How does it fit with existing workflows and standards
  • What happens when a case does not fit the model

If those questions do not have clear answers, it is usually a sign that process needs attention before technology.

 

Regulation still expects judgement, not just systems

It’s also worth remembering that regulators are not looking for firms to outsource responsibility to technology.

The FCA continues to emphasise accountability, suitability, and evidencing good outcomes. Systems can support that, but they do not remove the need for human oversight and professional judgement.

Tools that generate outputs still need someone to stand behind the advice, explain it, and evidence why it is suitable for that client.

That expectation is not going away.

 

Getting the balance right

The firms we see making the most progress are not chasing every new tool.

They are doing three things well:

  • Strengthening their core processes first
  • Using technology to support people, not replace them
  • Keeping experienced Suitability Consultants closely involved

That balance creates resilience. It also makes future tech changes easier to absorb, because the foundations are already sound.

 

Final thoughts

Technology will continue to evolve quickly. AI will become more capable. Platforms will keep changing.

But good advice still relies on clear thinking, professional judgement, and conversations between people who understand the realities of advising clients.

If this resonates with what you’re seeing in your own firm, we’d love to hear from you.  Got questions? Just reach out. No pitch, just people who get financial advice.

 

 

The start of the year often brings a strange mix of calm and movement in investment markets. Headlines are still coming through, capital is still flowing, but the tone feels more considered. Less noise. More intention.

This week’s updates from across infrastructure, alternatives, and growth capital all point to the same underlying theme. Money is still being deployed, but with clearer purpose and longer time horizons. For advisers and paraplanners, that matters. These are exactly the areas where client suitability, timeframes, and expectations need the most careful handling.

Here are a few reflections on what stood out this week, and what it might mean for advice conversations.

 

Natural capital moves from niche to normal

Foresight Group’s latest research shows that more than half of UK family offices are already investing in natural capital strategies. That is a meaningful shift. A few years ago, this sat firmly in the “interesting but early” bucket. Now it is becoming part of mainstream portfolio construction for sophisticated investors.

You can read the full piece here:

Over half of UK family offices already invest in natural capital strategies

What is notable is not just the uptake, but the motivation. These investments are not being framed purely as ESG statements. They are being positioned as long-term, inflation-linked, real asset exposures with diversification benefits.

For advisers, this raises familiar but important questions:

  • How well do clients understand the liquidity profile and time horizon?
  • Is the sustainability narrative driving the decision, or the underlying risk and return characteristics?
  • How clearly is the role of the investment articulated within the wider portfolio?

Natural capital can absolutely have a place in the right circumstances. But it relies on strong objective-setting and very clear suitability evidence, particularly where outcomes are long-dated and valuation is less transparent.

 

VCT fundraising continues, confidence with caveats

Puma Investments £20m raise for its Alpha VCT is another reminder that appetite for growth capital has not disappeared. Investors are still willing to back UK scale-ups, even against a more cautious economic backdrop.

The announcement is here:

New fundraise of £20m for Puma Alpha VCT to continue backing ambitious UK scale-ups

What we tend to see in practice is that renewed VCT fundraising often triggers two types of client conversation at the same time. Existing investors reviewing whether allocations still make sense, and new investors attracted by tax relief headlines without fully appreciating the risk.

This is where advice quality really earns its keep. VCTs, EIS, and Business Relief solutions are rarely unsuitable by default, but they are very easy to mis-position. The difference lies in how well advisers and paraplanners:

  • Anchor the recommendation to clearly evidenced objectives
  • Set expectations around timeframes, liquidity, and variability of outcomes
  • Demonstrate why this solution fits this client, at this point in time

The technical case is only half the job. The suitability story matters just as much.

 

A pause that feels intentional, not hesitant

Tatton Investment Management Limited’s recent reflection on taking a “quiet break from the new normal” captured something we are hearing repeatedly across firms.

You can read it here:

A quiet break from the new normal

There is a sense that many teams are deliberately slowing certain decisions. Not because confidence has gone, but because there is a desire to sense-check. To step back. To make sure last year’s assumptions still hold.

That mindset shows up clearly in suitability work. Files are becoming more reflective. Advisers are asking better questions earlier. Paraplanners are spending more time on context and less on post-rationalisation.

In our experience, this kind of pause often leads to better outcomes. It creates space to challenge default solutions and revisit whether a recommendation still genuinely serves the client’s longer-term needs.

 

Infrastructure keeps quietly scaling

Downing‘s expansion of its UK solar portfolio through ready-to-build projects is another example of capital quietly going to work in the background.

Details here:

Downing grows UK solar portfolio through ready-to-build projects

Infrastructure rarely grabs headlines in the same way as growth capital, but it plays a different role. Predictable cashflows, long-term contracts, and alignment with structural trends like energy transition.

Again, suitability is the anchor. Infrastructure solutions can be compelling for the right client, but only when:

  • The income profile matches the client’s actual needs
  • Concentration risk is properly considered
  • The recommendation is positioned as part of a balanced strategy, not a silver bullet

 

Pulling it together for advice teams

Across all four stories, the common thread is not excitement or fear. It is intentionality. Capital is moving, but with clearer reasoning behind it.

For advisers and suitability consultants, this is a good moment to reflect on a few practical points:

  • Are objectives being revisited often enough, or assumed to be static?
  • Is risk framed in plain English, not just risk ratings?
  • Do alternative and tax-efficient solutions have a clearly defined role, or are they filling a gap by default?

These are not new questions, but they matter most when markets feel quieter. That is when the quality of advice logic really shows.

If this resonates with what you are seeing in your own conversations, we would genuinely love to hear from you. No pitch. Just people who spend a lot of time thinking about how advice stands up when it really matters.

 

 

The first few days of January always feel a little unusual.

Inboxes are open again, but not loud. Diaries are filling, but cautiously. Conversations are restarting, often mid-sentence from December rather than charging into something new.

In the conversations I’ve been part of over the last few days, what stands out is not urgency. It is orientation.

Advisers are not rushing to make big calls yet. Instead, they are taking stock. Zooming out. Sense-checking where clients really are, and whether the advice conversations they were having last year still fit the full picture now.

That pause matters.

 

The full picture before the decision

One theme I keep coming back to, especially at the start of a year, is the importance of understanding the whole client context, not just the immediate planning problem in front of you.

Paul Muir touched on this recently when discussing the need to build a complete wealth picture rather than focusing on isolated assets or products. His point was simple, but powerful. Advice works best when it is grounded in the client’s wider reality, not just the part that happens to be under review right now.

You can read his piece here:

Paul Muir: Getting the complete wealth picture

What I’m seeing echoes that sentiment. Advisers taking a little more time to revisit objectives, reframe conversations, and check whether recommendations still make sense when everything is viewed together.

It is not about slowing down for the sake of it. It is about avoiding momentum-led advice.

 

Regulation as background noise, not the driver

There is already plenty of commentary about what 2026 may bring from a regulatory perspective. Expectations continue to evolve, and firms are rightly keeping an eye on where scrutiny and focus may land next.

Money Marketing recently explored how far-reaching some of these potential changes could be:

‘Far-reaching changes’: Regulatory outlook for 2026

From the conversations I’m hearing right now, most advisers are not reacting. They are observing.

Rather than jumping to implementation mode, many are asking quieter questions. What does good look like in our advice process? Where does consistency really matter? How do we make sure suitability is clear, not just defensible?

That mindset shift is encouraging. Regulation should inform good advice, not rush it.

 

Complexity has not gone away

Markets have not suddenly simplified because the calendar changed. Fixed income is a good example. Opportunities exist, but so do trade-offs, timing considerations, and suitability nuances that cannot be reduced to a headline view.

Professional Paraplanner recently outlined ten points advisers are considering when thinking about fixed income going into 2026:

Fixed income outlook 2026: 10 points to consider

What stood out to me was not the specifics, but the reminder that even familiar areas demand careful judgement. This is exactly why taking time early in the year to align advice logic, client objectives, and risk understanding pays dividends later.

Complexity does not need urgency. It needs structure.

 

What this early pause tells us

Taken together, these early signals suggest something positive.

Advisers are starting the year by thinking about:

  • the full client picture, not just the immediate task
  • clarity of rationale, not speed of output
  • consistency across advice, not just individual cases

That approach builds confidence. For clients, for advisers, and for firms.

It also makes the rest of the year easier. When the foundations are clear, later decisions feel less pressured and more intentional.

 

A gentle start is not a weak one

There is often an unspoken pressure to come back from the break with energy, plans, and answers. In advice, that is rarely where the best outcomes come from.

A steady start, grounded in reflection and context, is often the strongest one.

If this slower, more considered tone reflects what you are seeing in your own conversations right now, you’re not alone. And if you are still orientating rather than acting, that is not a problem to solve.

It is good advice practice.

If this resonates with what you are noticing at the moment, we would genuinely love to hear your perspective. No pitch, just people who care about financial advice.

 

This year has not been short on change. Global uncertainty, shifting markets, regulatory pressure, and evolving client expectations all shaped the reality of financial advice in 2025. But beyond the headlines, what really stood out to us were the quieter shifts. The way firms worked, the questions advisers asked, and the growing focus on doing the right thing first time.

Rather than offering predictions for next year, we wanted to reflect on this one. Not from a distance, but from inside the advice journey. Here are some of the moments and themes that stood out to our team.

Industry commentary this year highlighted how geopolitical change, interest rate movement, inflation pressure and rapid advances in technology all fed into advice conversations in very real ways . What we saw echoed that, but with a strong human layer on top.

 

What stood out to us this year

Paul Kenworthy

One of the biggest shifts I noticed this year was how suitability stopped being treated as a box-ticking exercise. Advisers were more willing to pause and challenge their own thinking, especially where risk, objectives, or product alignment were not as clear as they first appeared.

There was less defensiveness and more curiosity. More conversations that started with “does this really make sense for the client?” rather than “will this pass QA?”. That feels like real progress.

It also felt like firms were becoming more aware that consistency matters, not just across files, but across advisers. That awareness alone changes behaviours, and it is something I hope continues into next year.

 

Hannah Keane

For me, 2025 was the year Consumer Duty truly landed in practice. Not perfectly, and not without challenge, but it moved from being something people talked about to something firms actively worked through.

Advice discussions became more outcome focused. There was a noticeable shift away from explaining products and towards explaining rationale in a way clients could genuinely understand.

What stood out most was the number of advisers who wanted their advice to stand up, not just to scrutiny, but to time. That mindset shift, from compliance driven to client driven, is subtle but powerful.

 

Nicola Porter

From an operations and data perspective, this year highlighted how much the advice journey matters as a whole. Not just the advice itself, but how information is gathered, stored, revisited, and used.

We saw firms paying more attention to the quality of their data, how handovers worked, and where friction existed for clients. That is not glamorous work, but it makes an enormous difference.

When data flows properly and processes are clear, advisers get time back and clients feel more supported. The firms that leaned into that this year felt calmer, more controlled, and more confident in their advice delivery.

 

Lucy Wylde

This year really highlighted how much advisers value clarity. I saw more willingness to slow down and sense-check advice before it went out, especially where client circumstances were complex or evolving. There was less reliance on assumptions and more emphasis on making sure the logic genuinely stacked up. What stood out most was how collaborative the process became. When advisers, consultants, and teams work openly together, the advice is stronger, clearer, and far more defensible for everyone involved.

 

Claire Robertson DipPFS Certs CII (MP/ER)

What stood out to me was how open advisers became about pressure. Capacity, time, regulatory expectation, and client need all pulling in different directions.

Instead of pushing through at all costs, more advisers were willing to say when something did not sit right, or when they needed another perspective. That honesty leads to better advice.

I also noticed a growing respect for structured thinking. Clear objectives, clearer rationale, and fewer assumptions. It made collaboration easier and outcomes stronger for everyone involved.

 

The bigger picture

Industry reviews of 2025 highlighted how economic uncertainty, political change, interest rate movement and technology trends shaped planning decisions throughout the year . We saw that play out daily, but always through a human lens.

Clients wanted reassurance, not predictions. Advisers wanted confidence, not complexity. Firms wanted advice that felt robust, fair, and defensible without losing its personal touch.

What gave us confidence was not that everything was solved, but that conversations improved. Questions became better. Processes became more intentional. And advice became more considered.

 

Looking ahead, quietly

As we head into the Christmas break, we are not rushing to label next year as transformational. Instead, we are hopeful.

Hopeful that the focus on advice quality continues. That clarity keeps winning over speed. And that firms keep choosing structure and integrity over shortcuts.

To everyone we have worked alongside this year, thank you for the trust, the openness, and the conversations. We hope the next few weeks bring proper rest and a chance to switch off.

If any of these reflections resonate with what you have seen this year, we would genuinely love to hear your perspective. No pitch, just people who care about financial advice.

Wishing you a calm end to the year and a steady start to the next.

 

 

The FCA is simplifying the rules, but the bar for advice quality is rising

There has been a noticeable shift in tone from the FCA over recent weeks. Fewer new layers. More focus on making existing rules clearer and more effective.

That does not mean expectations are easing. If anything, the message is sharper.

The regulator appears less interested in firms navigating complexity for its own sake, and more focused on whether advice is genuinely suitable, well evidenced, and clearly understood by clients.

This week’s announcements span insurers, investment participation, financial crime, complaints handling, and ESG transparency. They may look disconnected. They are not.

Together, they point to a single direction of travel. Simpler frameworks, but stronger accountability for outcomes.

Here is what matters, and what it means for advice teams building and reviewing recommendations day to day.

 

Simplifying insurer rules, and what that signals for advice

The FCA has confirmed plans to simplify elements of its rules for insurers, with the aim of lowering costs and supporting innovation. Money Marketing covered this here: https://www.moneymarketing.co.uk/news/fca-to-simplify-its-rules-for-insurers/

While aimed at insurers, this has direct relevance for advice firms. Insurer costs and risk appetite shape product design, pricing, and availability. Over time, this feeds straight through to client outcomes.

More importantly, it signals something broader. The FCA is willing to remove complexity that does not improve consumer protection.

Advice firms should be asking the same question of their own processes. Where has complexity crept in that does not strengthen suitability or client understanding?

From an advice perspective, complexity should earn its place. If a justification exists only to defend a process, rather than explain a recommendation clearly, it is worth revisiting.

 

Encouraging investment engagement, without weakening suitability

The FCA has also reiterated its aim to improve the UK’s investment culture, encouraging broader participation while maintaining standards. Professional Paraplanner reported on this here: https://professionalparaplanner.co.uk/fca-to-boost-uk-investment-culture/

This matters for advisers supporting clients who may feel hesitant, cautious, or disengaged from investing altogether.

More participation does not mean lighter suitability. It means better explanation, clearer objectives, and advice that is easier for clients to understand and challenge.

This is where the role of a Suitability Consultant becomes particularly relevant. It is a role we developed to sit between advice construction and compliance oversight. The focus is on testing and evidencing suitability before advice is finalised, not reviewing it after the fact.

In practical terms, Suitability Consultants challenge assumptions, validate recommendation logic, and ensure the advice stands up on its own merits. Not because regulation demands it, but because clients deserve clarity.

 

Financial crime, proof now matters as much as intent

The FCA has launched a new firm checker to help consumers verify authorised firms and avoid scams: https://www.fca.org.uk/news/press-releases/fca-launches-firm-checker-fight-financial-crime

This sits alongside sobering data. Around 800,000 people reported losing money to investment or pension related scams in the year to May 2024.

For advice firms, this reinforces an uncomfortable truth. Clients often struggle to distinguish between regulated advice and fraud, until it is too late.

Good intentions are not enough. Firms need clear, documented processes that show how clients are protected. That includes identity checks, scam warnings, and how those conversations are evidenced.

From a suitability standpoint, being able to demonstrate what happened, when, and why, is becoming non negotiable.

 

Complaints reporting, simpler mechanics, same expectations

The FCA has also simplified the complaints reporting process: https://www.fca.org.uk/news/news-stories/fca-simplifies-complaints-reporting-process

This is a practical improvement. Less administration, particularly for smaller firms.

What has not changed is the FCA’s expectation that complaints data is meaningful. Complaints remain one of the clearest indicators of where advice processes break down.

Viewed through a suitability lens, complaints often trace back to unclear objectives, misunderstood risk, or recommendations that were not fully anchored to the client’s circumstances.

Simpler reporting removes noise. It puts the focus back where it belongs, on learning and improvement.

 

ESG ratings, clarity over claims

Finally, the FCA has set out proposals to regulate ESG ratings providers: https://www.fca.org.uk/news/press-releases/fca-proposals-esg-ratings

This reflects growing concern about inconsistency and vague claims in sustainable investing.

For advisers, ESG is firmly a suitability issue. It requires clear documentation of client preferences, an honest assessment of how products align, and transparency about limitations.

Suitability Consultants spend a growing amount of time here, stress testing whether ESG claims are properly evidenced, not assumed. This is exactly where future complaints and regulatory scrutiny will focus.

 

The bigger picture

Across all of these updates, the FCA’s message is consistent. Reduce unnecessary complexity, but raise expectations around clarity, evidence, and outcomes.

For advice firms, this is not about adding more checks. It is about building suitability into the advice process from the outset, so files stand up without explanation or repair.

Clear objectives. Defensible logic. Plain English. Evidence that speaks for itself.

If this reflects what you are seeing in your firm, or the direction you feel the industry is heading, we would genuinely love to hear from you. No pitch, just people who understand the realities of delivering good advice.

 

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

 

 

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