News

A practical look at whether file checking is doing what advisers think it is doing.

Open a handful of completed files at most advice firms and you’ll find evidence the check happened: a sign-off, a tick, a reviewer’s initials. Some cases are checked before they go out, some are sampled afterwards, and some get extra review depending on the type of advice or who worked on the case.

What’s harder to find is evidence that the check would have caught anything. Knowing a file went through checking doesn’t tell you whether the checking works.

The issues that cause the most friction on files are rarely dramatic. More often it’s a figure that differs between two documents, an older version sitting alongside the current one, a missing piece of evidence, or a question that was answered somewhere but not recorded clearly enough for the next person to follow. Those things make a case harder to construct properly even when nothing looks wrong at first glance.

Tony explores this in the latest paper in our Advice, Evidence & Judgement series. Rather than measuring a control by whether it was completed, the paper suggests occasionally testing the control itself.

Plant something on purpose

Take a completed case that’s safe to use for testing, make a working copy and deliberately change one important thing. You might give it two conflicting versions of a client objective, strip out the evidence behind an assertion, leave an older risk assessment next to the current one, take out a sign-off that should be mandatory, or add an unexplained cost difference between two possible recommendations. Then put the case through the normal review process.

You’re testing the process, so it’s worth telling reviewers nobody is being marked. What you want to know is whether it reacts the way you assumed it would, which tells you whether the checking picks up the sort of issues that make technical planning harder. It also separates a process that adds value from one that just confirms a checklist was completed.

Not every difference should produce a failure. Sometimes the right response is a question, a request for more evidence or no challenge at all, and a reviewer who challenges everything isn’t doing the job well either.

Look at what happened after the issue was found

Recording “caught” or “missed” doesn’t tell you much about the quality of the process. Say a reviewer spots two different withdrawal figures. You’d want to know whether the problem was described correctly, whether the challenge was linked to the right document, and whether anyone resolved it. If the adviser explained why one figure was right, did that explanation stay visible in the file? And if the system raised something that wasn’t a problem, that deserves a note too, because a control that flags everything creates more work without necessarily creating better advice.

Keep it small

You don’t need a big testing programme. Start with three past cases representing different advice situations, introduce one known issue into each and put them through the normal route. On a retirement income case, that might be a withdrawal figure in the report that no longer matches the cashflow model. On an investment switch, it could be last year’s risk questionnaire left in the file next to the current one with a different score. On a tax-efficient investment case, it could be a mandatory sign-off taken out. Each one is a quick edit to a working copy of a file you already have.

Ideally one of the three contains something that looks unusual but shouldn’t result in a challenge, such as a portfolio carrying more risk than the client’s attitude to risk would suggest, where the file clearly evidences their capacity for loss and their reasons.

That’s a manageable exercise for most firms, and it gives you a better question than “how many files did we review?”: what have we learnt about what our process can actually detect? This gets more pressing as firms bring technology into review and quality assurance, because a dashboard can show every case was processed without showing whether it would spot the missing evidence or conflicting objective you assumed it was looking for. The FCA makes a similar point in its work on outcomes monitoring: collecting data and producing reports isn’t enough on its own, and firms need information that helps them identify poor outcomes, understand the causes and act on them.

One question to take back to the team

Next time file checking comes up, try asking:

If we deliberately put something wrong into a test case, how confident are we that our normal process would find it?

Tony’s full paper, Would your file checks catch a mistake you planted?, includes practical examples and a simple first exercise firms can run.

AI is moving into financial advice at some pace. Research reported by FT Adviser in July found that the proportion of UK financial advisers using AI had risen from 43% to 74% in just twelve months, based on an Intelliflo survey of 209 advice professionals. That is a fairly significant shift in a relatively short period of time.

It probably does not come as much of a surprise. There are more tools available, they are getting better and firms are naturally interested in where they can make processes easier, remove repetitive work or help people get to the information they need more quickly.

Most providers will give you some kind of demonstration before you buy, and increasingly there is the option of a free trial as well. Both are useful. Seeing a system in action is important, and having a few weeks to put it through its paces is even better.

The problem comes if the test stops at whether the demo looked good or whether the first few outputs were impressive.

The more useful question is: what happens when you put your own work through it?

Real files are rarely as tidy as a demo

Anyone involved in technical planning will know that a live advice case does not always arrive as one neat bundle of perfectly consistent information.

A meeting note might refer to one level of income while a fact-find shows another. There may be two versions of an illustration in the file and it is not immediately obvious which one informed the final recommendation. A client’s objective may have changed during the advice process without every document being updated to reflect it. Sometimes the information is all there, but it is spread across provider correspondence, meeting notes, research and emails rather than sitting neatly in one place.

None of those things necessarily mean there is a problem with the advice. They are simply examples of the reality of working with information that has been gathered from different places, by different people and at different points in time.

There is also another type of case our technical planners regularly have to deal with: one where there is no obvious black-and-white answer. Two options may both be perfectly reasonable, but one works better because of something specific about that client. The important bit then is not simply whether the system can find the facts. It is whether the evidence and reasoning are clear enough for a professional to make, and later explain, that judgement.

That is where an AI tool starts to get a much more meaningful test.

Use the awkward cases

If you have a month to trial a system, it makes sense to use that month properly.

There will always be a temptation to start with straightforward cases because they are easier to compare and you want to understand how the system works. There is nothing wrong with that. But once you are comfortable with it, the awkward cases are probably going to tell you much more.

Put through something where documents conflict. Try a case with a piece of missing evidence. Use one where an older version of a document sits alongside the current one. Include a case where you already know there was a genuine judgement call to make.

Then look at what actually happens.

Did the tool notice the inconsistency? Did it rely on the right document? Did it challenge something that was already adequately evidenced? If it raised a concern, could the person reviewing the case see why? And just as importantly, if there was nothing wrong, did it leave the case alone rather than manufacturing a problem because it felt obliged to find one?

That is very different from asking whether an overall output looked good.

Tony explores this in the latest paper in our Advice, Evidence & Judgement series. Rather than beginning with a headline accuracy percentage, the paper suggests starting with a varied sample of cases and looking carefully at the failures: material gaps that were missed, unnecessary challenges, whether findings were grounded in the correct evidence and whether a reviewer could see what happened when professional judgement came into play.

A polished answer can still be wrong

This is one of the things that makes generative AI particularly interesting in advice.

The output can be extremely convincing.

A system can take a large amount of information and turn it into something clear, well structured and professional very quickly. That can be enormously useful. But it can also make a weak answer look much stronger than it actually is.

A beautifully written paragraph does not tell you whether the system has picked up the correct version of the illustration. A confident explanation does not tell you whether it has missed a contradictory meeting note. A sensible-sounding challenge does not tell you whether the evidence it says is missing was actually sitting elsewhere in the file.

Our technical planners would not accept something as correct simply because it was well written, and firms should probably apply the same thinking when evaluating technology.

The question becomes less about how good the output looks and more about whether you can follow it back to the evidence that supports it.

Testing AI is not about being cautious for the sake of it

There can sometimes be a sense that conversations about testing and controls are somehow anti-innovation. I do not think they are.

The FCA itself is actively supporting firms experimenting with AI through its AI Lab. Its AI Live Testing programme provides firms with a place to test AI systems in real-world conditions, and participants are expected to have considered both pre-deployment testing and how systems will be monitored after deployment. The FCA describes its wider aim as enabling the safe and responsible use of AI while supporting growth and innovation.

That feels like a sensible distinction.

The question is not whether AI should be used. It already is, and the numbers suggest adoption is moving quickly.

The question is how firms become confident that a tool is doing what they think it is doing once it becomes part of a real advice process.

A free trial gives firms a really useful opportunity to start answering that question, but only if the testing reflects the work the system will eventually be expected to deal with.

What would you want to know before relying on it?

Tony’s paper includes ten questions firms can use when looking at an AI tool, covering things such as what cases an accuracy claim was measured against, how disagreements were handled, whether findings can be traced back to the underlying evidence and whether firms can test representative cases of their own.

For me, though, the principle underneath all of them is quite simple.

The point of testing an AI tool on your own files is to get a much clearer picture of how it actually behaves in your advice process, not just how well it performs in a demonstration.

As AI becomes a bigger part of how advice is prepared, researched, reviewed and evidenced, being able to understand that difference is going to matter.

Read Tony’s full paper: Advice, Evidence & Judgement | We Complement

External reading: FCA AI Lab

Source referenced in the introduction: FT Adviser article on AI adoption among UK advisers

There’s a stage in an adviser’s career that seems to get much less attention than the exams that come before it. You’ve done the studying, passed the exams and you’re working towards being able to advise independently. On paper, there’s a route through qualification and Competent Adviser Status, but in practice the bit where you actually learn how to do the job is much less straightforward.

Knowing the technical answer is one thing. Sitting in front of a client and knowing which questions to ask, when to probe a little further, how to deal with a conversation that goes off in a direction you weren’t expecting, and what information the rest of the advice team will need from you afterwards is something completely different. That part comes with experience, and how much support you get while you build that experience can depend a lot on the firm you join.

Some larger firms have built a lot of structure around that journey. They have academies, mentors, supervised client work and experienced people whose job it is to help new advisers develop. Smaller firms can offer brilliant experience too, and in some ways a new adviser may get more exposure to the whole business, but they don’t always have the same infrastructure sitting behind them. Often, the person doing the mentoring is also running a client bank, managing staff and trying to keep the business moving.

That’s the part I’ve been thinking about lately. When a firm takes on someone who is still developing, those early cases naturally need more time and attention. There are more questions, more checking and more conversations around why something has been done in a particular way. That’s exactly how it should be, but it can put pressure on the people around them, particularly in a smaller business where there may only be one or two experienced advisers available to provide that support.

It made me wonder whether there’s a role for We Complement in the work that sits around development, without stepping on a firm’s own training and competence arrangements or getting anywhere near CAS sign-off.

The fact-find is one obvious example. Our team sees what happens to a case once the client meeting is over. We see which gaps in information lead to more questions later, what makes a file straightforward to research and write, and what tends to result in somebody having to go back to the adviser for more detail. It’s a view of the advice process that newly qualified advisers don’t always get to see, and I think there could be real value in sharing some of that earlier.

That doesn’t need to become another formal training programme or compliance checklist. It could be as simple as showing someone what a strong fact-find looks like from the point of view of the person picking it up afterwards, and explaining why certain details matter. It might work as a short guide, a session with an academy cohort or something more informal for a group of advisers who are still finding their feet.

There’s also the wider capacity issue. If an experienced adviser is spending more time mentoring and reviewing early cases, something else in the business still needs to get done. Paraplanning, research, processing and admin don’t disappear while someone is developing. That’s where I can see a role for flexible support, helping to take some of the pressure elsewhere so the people inside the firm can spend their time where it’s most valuable.

I’ve been looking at how different firms approach this, from larger academies through to newer propositions such as Evergreen, and there clearly isn’t one model that works for everybody. I also came across a Money Marketing piece on Competent Adviser Status which makes the point that qualification is only one part of the journey. The practical experience that follows matters just as much, which feels obvious when you work in advice, but perhaps less obvious from the outside looking in.

What I keep coming back to is the smaller firm that wants to develop its own next adviser but doesn’t have an academy sitting behind them. We don’t have a finished answer to that, and I don’t really want to invent one from our side of the desk. I’d much rather understand what firms and advisers actually find difficult during that stage and see whether there’s something useful we can build around it.

So if you run an academy, mentor advisers working towards CAS, or you’re a smaller firm developing someone new, I’d really like to hear what that experience looks like for you. And if you’ve been through it yourself in the last few years, what’s the one thing you wish somebody had shown you earlier?

More than one adviser has told us the same thing recently. Their annual reviews are deliberately booked into the same few weeks every year. Ten, fifteen, sometimes twenty reviews, all planned that way well in advance. And actually, it makes a lot of sense. Once a review is booked, it tends to stay exactly where it is. Advisers protect that hour, and rightly so, because it is the part of the process the client actually sees.

What is harder to protect is everything built around it: provider information gathered, valuations chased, client records updated, files prepared, any technical work completed, recommendations implemented, and someone making sure it all actually gets followed through. One review at a time, spread across the year, that can feel manageable. Ten of them landing together is a different problem, and it is bigger than it looks on paper.

Put a number on it

Across the review work we support, a fairly standard case will often involve around five hours of admin and paraplanning time in total, split either side of the meeting itself. Roughly two hours might go on admin beforehand, gathering provider information, pulling valuations and preparing the file. After the meeting, report writing and paraplanning can take around another two hours, with implementation and updating records adding roughly another hour.

Ten standard reviews booked into the same month therefore means around 50 hours of admin and paraplanning work landing around those meetings, on top of whatever else is already sitting with the team. Even that understates it, because a review is not one task, it is a sequence: gather, prepare, meet, report, implement, chase. Each stage depends on the last one finishing, so once several reviews are moving through the process at once, they start to queue behind whichever stage is slowest.

That is often where the real problem sits. Ten reviews rarely feel like ten times the work. They feel like everything backing up behind one narrow point while the meetings booked months ago carry on regardless.

Why batch them at all?

There is no one right way to structure annual reviews. Some firms spread them across the year, while others deliberately work in surges and group them into known periods. Both can work. The real question is whether the rest of the process has been designed around that choice and whether anyone is actually watching where the queue builds.

The hours do not always tell you where the problem is. The gaps often do. How long does a case spend waiting for a valuation, waiting for technical work, or waiting to be implemented compared with the time someone is actually working on it? That waiting time can quickly become the real capacity problem.

A useful way to test your own process is to look at the last five reviews you completed. Do not just record how many hours they took. Look at how many days passed between each stage and where each case spent the longest waiting. If every case spends three days waiting for provider information, adding another paraplanner will not necessarily solve the problem. If everything reaches the same technical reviewer at once, speeding up the admin beforehand might actually make the queue worse.

Where we actually fit

We do not think every firm needs to run annual reviews the same way. Some want help with the whole process. Others only need support with provider information, report writing, implementation, or just the weeks where workloads spike.

We have never been in the room for the review meeting itself, and that is deliberate. That is the adviser’s conversation to have. What we can do is support the work around it, from arranging the meeting and gathering information beforehand through to suitability work, implementation and follow-up after. Our annual review service was built around exactly that split. Some firms hand us most of the process, while others only hand over the part that is creating the bottleneck. Either way, the adviser keeps the client relationship.

It is not always about how many reviews you have

The more annual review conversations we have, the less I think the interesting question is “how many reviews do you have?” and the more it is “how much of each review still sits with the adviser?”

A firm can have a perfectly manageable number of reviews on paper and still feel stretched if the adviser is carrying the preparation, technical work, meeting, documentation and follow-up alone. If reviews are already planned months in advance, that is also the moment to decide who does each part of the work, before the batch lands rather than during it.

If your reviews are already scheduled in one batch every year, which stage backs up first once that window opens: the admin before, the paraplanning after, or the implementation and records once it is all agreed?

So, being the geek that I am, the first thing I did at 6:30 this morning, after the cat woke me up at 5:30 wanting to go outside and kill things, was download the NextWealth Financial Advice Business Benchmarks Report 2026.

There are probably more exciting ways to start a Friday, but one figure in the “people and capacity” section really caught my attention.

NextWealth says onboarding a typical client takes around 32 hours of human time across the whole team. Of that, admin accounts for eight hours and paraplanning for seven, so 15 hours combined before adviser and compliance time is added in.

We do exactly that slice of the work for a living, so naturally I wanted to know what our own numbers looked like.

What our own data says

Because we track time against the work we do, I was curious to see what our own numbers looked like next to the NextWealth benchmark. Across our casework this year, (631 cases and counting) our average admin and paraplanning time comes out at around 6.8 hours per client.

On the face of it, that’s less than half NextWealth’s 15-hour figure. But it isn’t quite a like-for-like comparison, and that’s actually where it gets interesting.

NextWealth’s figure relates specifically to onboarding a typical new client. Ours is a blended average across the different types of work firms send us, from more straightforward reviews and switches through to much more involved pension and specialist planning cases.

So I wouldn’t use 6.8 hours to claim we’re somehow “twice as fast”.

What I do think is useful is that we know our number at all. Because when you track the time properly, you start to see very quickly which work is taking longer, which types of case use the most capacity and where the hours are actually going.

The average hides a lot

That 6.8-hour figure is only useful if you remember it’s an average. Some of the more straightforward work we see can sit around the 4 to 5-hour mark. More complex planning cases, IHT work or pension cases with several moving parts can easily be much higher.

Neither end of that range is “right” or “wrong”. It’s just different work.

That’s probably one of the biggest problems with any single benchmark for paraplanning time. A straightforward review and a complex pension case can both be called a “case”, while the amount of work involved can be completely different. So for me, the more useful question isn’t whether your number is 6.8 hours or 15.

It’s whether you actually know what your own number is, and what sits behind it.

Why might our number be lower?

This is the bit I’d be careful not to overstate. I don’t think our data proves that outsourced paraplanning is automatically faster than an in-house team, because it doesn’t.

But specialisation probably plays a part.

Our team spends most of its working week doing this type of work across different firms. Research, suitability reports, reviews, pension cases, investment work. It is the main job rather than one task competing with everything else that lands that day.

One thing we do see is the effect of interrupted work. If someone is researching a case while also dealing with client queries, internal meetings, admin, system issues and whatever else has appeared in the inbox, there is naturally more stopping and starting.

That’s not a criticism of in-house teams at all. There are brilliant internal paraplanning teams that will be every bit as efficient.

It’s simply one possible reason why a dedicated team doing the same type of work repeatedly might see a different average.

This is where the operational bit matters

For Heads of Paraplanning and Ops Managers, I think the more useful question is not:

“Should our cases take 6.8 hours or 15?”

It’s:

“Do we actually know how long they take?”

Because if you don’t know that, it becomes very difficult to work out where the pressure is really sitting.

Is a paraplanner spending five hours on technical work and another two on admin?

Is research being redone because information is missing?

Are advisers chasing providers when that work could sit elsewhere?

Is the team genuinely short on capacity, or is too much time disappearing into work that doesn’t need to sit with them?

That’s the sort of thing we end up talking through with firms all the time. And because most of our work is charged hourly, we get a pretty clear view of it.

Our paraplanning and technical support is currently £75 + VAT per hour, while admin support is £55 + VAT per hour.

That means both we and the firms we work with can see what different parts of the process are actually costing in time, rather than just looking at one overall salary or cost figure.

Cost to serve is becoming a much bigger conversation

The wider NextWealth report backs that up. 40% of firms have reviewed the cost to serve a typical client in the last 12 months, and another 25% plan to. The report also shows firms making much more deliberate decisions around which clients they serve, how they serve them and what those relationships actually cost.

That’s probably the bit I think is most useful for business owners.

You can know your revenue per client down to the pound, but if you don’t know how many hours of adviser, paraplanning, admin and compliance time sit behind that revenue, the picture is still incomplete. And the same applies to growth.

More clients only works if the delivery model underneath them can actually cope.

The bit I’d check in your own numbers

If you head up paraplanning, run operations or own an advice firm, I think this report is a pretty good prompt to pull your own data.

Not because you need to beat 15 hours.

And not because 6.8 is some magic target.

But because your own number tells you something useful about how your business is actually working.

I’d be looking at average research and paraplanning hours by case type, rather than one blended total. I’d also want to know how much technical time is being lost to admin or chasing, and whether the same people are regularly doing work below their skill level because there is nobody else available to pick it up.

That’s where the interesting conversations usually start.

Money Marketing’s coverage of the report picked up on the same wider theme, with firms repricing and segmenting client books as cost-to-serve becomes more important.

And the full NextWealth Financial Advice Business Benchmarks Report is well worth a look if you work in operations, paraplanning or run an advice business.

Where I land on it

I’m not the one logging the time against every case. That’s down to the team and the system they use. But I do like being able to put our own numbers next to a national benchmark rather than just saying “we’re efficient” and expecting people to take our word for it.

Our 6.8 hours doesn’t prove we are faster than everyone else. What it does show is that we know what our work takes, we track it properly, and we can see how much the answer changes depending on the type of work involved.

That feels like a much more useful conversation to have with firms.

If you want to see what outsourced research and paraplanning looks like against your own case volumes, we’re always happy to put real numbers on the table.

Ours and yours.

I’ll be upfront: I’m not the one building cashflow models or picking apart suitability files. That’s the rest of the team. But after sharing Cecilia Furner’s piece on better retirement outcomes for women yesterday, I ended up going down a bit of a rabbit hole with the research, and one thing stood out almost immediately.

The gender pension gap is usually talked about as a retirement problem. Something that becomes obvious at 60, when somebody suddenly realises their pension looks very different from their partner’s. By that point, though, there’s often not a huge amount of time left to change the outcome, which makes the more useful question when the warning signs actually start appearing.

And I’ll admit, some of the ages in the research made this feel a bit more personal than I expected.

I’m 41, I have three children and I’ve got a career that I genuinely love and really value. But it has taken time to get here. Like a lot of families, there have been periods where decisions around work, children, childcare and what made sense financially had to be made as a household. My husband’s income has done more of the heavy lifting financially at different points, and that doesn’t mean my career has mattered any less to me. It just means our working lives haven’t followed exactly the same path.

That is probably why the research around when the pension gap starts to develop caught my attention.

AJ Bell’s research points to age 28 as one of the first places pension priorities begin to diverge. Before then, pensions barely register as a high financial priority for either men or women, with just 6% of women and 9% of men ranking them that way. It’s a small difference at that stage, but it’s interesting because it’s happening years before most people would consider themselves to be doing any serious retirement planning.

The bigger shift seems to come later. Professional Paraplanner reported on Aviva research covering more than five million pension plans, which found the gap widening from 21% in the late thirties to 32% by the early fifties. Aviva pointed to age 35 as a particularly important point, not because something suddenly happens on somebody’s 35th birthday, but because that tends to coincide with the years when career breaks, reduced hours and caring responsibilities become much more common.

That age really resonated with me. Your thirties can be such a busy period of life that I’m not sure many people are stopping to think about the impact a decision today might have on their pension 25 or 30 years later. You’re thinking about nursery bills, school runs, mortgages, whether somebody needs to finish early on a Wednesday and who has the job with a bit more flexibility. Pension compounding is probably not top of the WhatsApp conversation.

By age 60 to 65, women’s pension pots average around 57% of men’s. That’s a pretty big gap to discover when retirement is already on the doorstep.

Career breaks are a big part of the picture

This isn’t simply about women choosing to put less into a pension. A lot of the difference comes from what happens around work. Women are much more likely to take time away from employment for childcare, reduce their hours or step back from progression for a period, and those are exactly the years when missed contributions have the longest time to matter.

One estimate suggests a five-year career break beginning at 35 could reduce someone’s pension by around £69,000 by retirement. That was the part that really jumped out at me. Missing contributions then doesn’t just mean missing the money that would have gone in, it also means losing years of potential growth on those contributions.

I also think the language around this matters. “Career break” can make it sound as though somebody simply decided to put their career on hold. Real life is usually much messier than that. It might be maternity leave followed by reduced hours because childcare costs are enormous. It might be choosing the job that works around school rather than the one that offers the next promotion. It might simply make more financial sense for one person’s career to take priority for a few years.

None of those things necessarily feels like a big pension decision at the time. Usually, they just feel like normal family decisions.

And I think that’s part of the problem. The pension impact is happening quietly in the background.

Some of the things that can help are surprisingly simple

Reading through the research, I kept thinking that some of this is information people could really do with much earlier. A non-earning partner can still have up to £3,600 gross paid into a pension each tax year, including basic-rate tax relief. Child Benefit can also protect National Insurance records and therefore State Pension entitlement, provided the claim is made correctly.

There are other small things worth checking too, like what actually happens to workplace pension contributions during parental leave rather than simply assuming they stop. None of these things fixes the gender pension gap on its own, but over 20 or 30 years, small decisions can make a meaningful difference.

And I wonder how many women would make different decisions if somebody simply pointed these things out at the right time.

I certainly don’t remember sitting in my twenties thinking about whether the choices I would make around work and family in my thirties might eventually affect my retirement income. I was thinking about building a career and paying the bills in front of me. I suspect I’m not particularly unusual in that.

Where this becomes an advice issue

This is probably the bit that interests me most from a We Complement point of view. The gender pension gap isn’t really a separate issue that suddenly needs discussing with women at retirement. It’s something that can show up much earlier in ordinary retirement planning.

If somebody has had a career break, moved to part-time hours or spent several years making lower contributions, has that actually been reflected in the cashflow modelling? If one partner’s pension is significantly smaller than the other’s, does the plan recognise why? And if a couple are being advised together, is it still clear what each of them owns and what their individual retirement position looks like?

That last point feels particularly important to me.

As somebody who is married, I naturally think about our finances as ours. We’re a household and we make decisions as a household. But that doesn’t change the fact that we are also two individuals, with two careers, two pension histories and potentially two very different retirement positions.

Looking at household pension wealth as one big number can make a plan look perfectly comfortable while hiding a very different picture for the two people sitting in the room. That might never become an issue, but divorce, bereavement or simply wanting to understand your own financial position can suddenly make the distinction quite important.

And I don’t think recognising that somehow undermines joint financial planning. If anything, it makes it better.

The file should tell the story too

This is where the paraplanning and suitability side comes in. A good retirement recommendation shouldn’t just show where the client is now. The reasoning behind it should also make sense in the context of how they got there.

Career breaks, reduced earnings, gaps in contributions, changes in working patterns and different levels of pension provision between partners are all part of the client’s financial history. If they’re relevant to the recommendation, they should be visible in the thinking behind the advice rather than simply sitting quietly in the fact find.

We see plenty of cases where two clients look quite similar at first glance. Same age, similar retirement date, similar objectives. But once you understand the years that came before, the planning needs can look very different.

And perhaps that is where advisers can make the biggest difference. Not by telling somebody at 60 that there’s a gender pension gap, but by noticing the things that could create one while there is still time to influence the outcome.

Maybe 35 is the age worth remembering

I don’t think advisers need to suddenly start having a separate “gender pension gap conversation” with every female client. But I do think there’s something useful in the ages the research keeps pointing towards.

If the gap is beginning to emerge in someone’s late twenties and then widening more noticeably through their thirties and forties, those are the years when there is still plenty of time to do something about it. Waiting until 60 to spot it feels a little late.

And perhaps this is the bit I see differently now that I’m 41.

At 28, retirement felt miles away. At 35, life was busy. Now, at 41, my eldest has finished school and I can look back and see how lots of perfectly ordinary decisions made over those years could shape what someone’s finances eventually look like.

So perhaps the useful question at review isn’t simply “How much is in the pension?”

pension?”

It’s “What has happened since we last looked at the plan, and has that changed where this client is heading?”

Because the gender pension gap may become most visible at retirement, but the decisions that help create it are often made decades earlier, usually while people are thinking about everything except their pension.

And that, for me, was the biggest thing I took from the research.

We’ve reviewed plenty of suitability files over the years that say some version of the same thing: the pension sits outside the estate, so it is the last pot to draw from in retirement and the first one left alone.

That way of thinking became especially embedded after the pension changes introduced from 2015, when pensions became much more attractive from an estate-planning point of view. So although the 2027 changes are significant, this is not entirely new territory. In some ways, pensions are being pulled back into an IHT conversation they have increasingly sat outside of for the last decade.

From 6 April 2027, most unused pension funds and pension death benefits will be brought into the value of a deceased person’s estate for inheritance tax purposes. Personal representatives will be responsible for reporting and paying any IHT due, while pension scheme administrators will also have new information-sharing and payment responsibilities. The main reform is now legislated for, although HMRC is still publishing the practical detail and guidance ahead of implementation.

That is the headline everyone knows. The bit I think is more interesting is what happens next.

The part nobody really signs up for

At the moment, pension death benefits often sit outside probate and personal representatives may have very little to do with them. From April 2027, that changes quite significantly. The person administering the estate may need to contact pension schemes, establish what pension benefits exist, obtain values, work out whether any of those benefits are exempt, complete the IHT account where one is needed, and make sure the right amount of tax is paid.

That person is quite often a spouse, an adult child or a friend who agreed to be executor years ago and probably did not imagine they would one day be dealing with HMRC and several pension providers at the same time. HMRC’s latest technical note gives more detail on how that process is expected to work. Pension scheme administrators will generally have 28 days to provide core information once they receive a valid request, with separate timings applying where beneficiaries have not yet been decided.

There is also a new withholding mechanism. If the personal representative reasonably believes IHT may be due, they can ask the scheme to withhold up to 50% of the relevant pension death benefit for up to 15 months after the end of the month in which the member died. Where a valid Pensions Direct Payment Scheme notice is served, the scheme administrator has 35 days to make the payment to HMRC.

None of that is impossible, but it is not exactly intuitive either, especially if you have never administered an estate before.

The tax is one thing. The admin is another.

I think that is the bit advisers need to get ahead of. The tax position is relatively easy to explain. The process is messier. A client may have several pension schemes, old workplace arrangements, a SIPP, expression of wish forms that have not been looked at for years, and beneficiaries spread across different parts of the family. Their executor may not even know all of those pensions exist.

That is why this feels like a review conversation rather than something to leave until 2027. Who is nominated to receive the pension? Does that still make sense? Does the executor know where the pensions are held? Does the wider retirement plan still assume the pension will be left untouched because it sits outside the estate?

Those are fairly simple questions to ask now. They may be much harder questions for somebody else to answer later.

There is also an important interaction with income tax. The rules are being designed so that, where IHT has been paid on pension benefits, the same slice of benefit should not effectively suffer tax twice. HMRC’s technical notes set out how IHT and income tax are intended to interact and how beneficiaries may be able to recover income tax where appropriate.

That is sensible in principle. In practice, it may still become quite complicated where benefits are split between several beneficiaries, paid in different forms or taken over more than one tax year. Again, not something most personal representatives are going to be familiar with.

This is happening

There was a lot of pushback when the change was first proposed, but the main reform is now in legislation and the new regime applies to deaths on or after 6 April 2027. HMRC is still publishing secondary legislation, guidance and practical materials, so some of the process detail will continue to develop between now and then.

For planning purposes, though, April 2027 is not something I would treat as speculative anymore. It is coming.

Why I think this belongs at the next review

There are advisers who are already very much on top of this. We are seeing firms actively reviewing pension nominations, retirement income strategies and wider IHT planning with clients now, rather than waiting for April 2027.

But we are also still hearing versions of “we’ll deal with that next year”, and that is the bit I would be wary of.

There is no need to turn every annual review into a full IHT exercise, or start changing perfectly sensible plans simply because the rules are moving. But expression of wish forms written years ago may need another look. Retirement strategies built around leaving the pension untouched until last may need reconsidering. Clients may also want to think about whether the person administering their estate actually knows what pension arrangements exist and where they are held.

None of that needs to wait until 2027. It is really about checking whether the assumptions sitting behind the plan today will still make sense under the rules the client is heading towards.

For me, the most useful thing an adviser can do now is make sure the conversation has happened and the file shows the client understood what is changing. Because the tax calculation is not the bit I would worry about most. It is a grieving spouse or adult child finding a pension scheme they did not know existed, with a deadline already running, trying to work out what HMRC needs from them.

That is the bit worth getting ahead of.

Where this leaves advisers

The point is not to turn every annual review into an IHT exercise. It is simply to make sure the assumptions sitting behind the retirement plan and the suitability file still make sense under the rules clients will actually face.

If this is something you are starting to think through with clients, we are always happy to be a second pair of eyes. You can read a little more about our tax-efficient investment support and wider suitability consulting support if useful, or just get in touch if you want to talk a case through.

I’m not a paraplanner. I don’t write suitability reports, and I wouldn’t pretend to know what should go in every section of one. But I talk to a lot of people who do, and there’s a slightly awkward question that comes up more often than you might think.

A suitability report is usually read properly by the paraplanner who wrote it, the adviser who checks it and, depending on the firm, compliance too. What is much harder to know is how much of it the client actually reads. From the conversations we have with firms, there’s often a suspicion that clients focus on the summary, the recommendation and the cost, rather than reading every page from beginning to end.

That isn’t a criticism of clients. Most people do not want to spend their evening reading page after page about their own circumstances in language they do not use every day. What they really want to understand is fairly simple: did you understand my situation, what are you recommending, why, what is it going to cost me, and do I trust the advice?

So who is the report actually for?

The truth is, it is doing two jobs at once. It has to help the client understand the recommendation in front of them, and it also has to create a clear record of why that recommendation was suitable.

Both matter. The problem starts when the second job begins to overwhelm the first.

We see this most clearly when we start working with firms that have been using the same report template for years. A paragraph gets added after one case. Another gets added later because something once felt like it should have been covered. Then a disclosure appears because someone worries it might be needed one day. None of that is bad practice. Usually, it comes from a perfectly reasonable desire to make sure nothing gets missed. But over time, the report grows, and it’s often not until a new firm sits down with us and sees their own template laid out fresh that they notice quite how much it’s grown. More than one has told us that they’d rather start again with ours than keep adding to their own.

How reports gradually get longer

At some point, it becomes worth asking whether every section is still helping this particular client understand this particular recommendation. That is often part of the early work we do with firms through our suitability consulting support, not cutting things just for the sake of making a report shorter, but asking what each section is there to do and whether it still earns its place.

Because client understanding is not the same thing as information volume.

That is close to what the FCA’s Consumer Duty guidance on consumer understanding is getting at too. The aim is not simply to disclose information, but to communicate it in a way the customer can understand, at the right time, so they can make an informed decision.

Client understanding vs evidence

Some cases absolutely need detail. Some clients want more explanation than others. There will always be parts of the file that exist because the advice needs to be properly evidenced.

But pretending every paragraph is there for exactly the same reader, doing exactly the same job, probably does not help anyone.

A good suitability report should be able to do both: explain the advice clearly to the client and evidence the reasoning properly for the file. The challenge is making sure one does not drown out the other.

If a client read the whole thing, would they understand it, or would they just feel like they’d been told something very thoroughly?

Sound familiar? Whether it’s a template that’s grown well beyond what any client actually needs, or a nagging feeling that nobody’s quite sure who the report is written for anymore, it might be worth a second look. We’re always happy to talk it through, no obligation, just a conversation about what’s actually needed and what isn’t.

On 13 July 2026, the DWP and the FCA published an updated consultation on a Value for Money framework for workplace pension schemes, focused initially on default and quasi-default defined contribution arrangements. It’s built around comparing schemes on cost, investment performance and service quality together, rather than cost alone. The consultation closes on 1 September 2026, with the FCA expecting the first larger schemes to complete assessments from 2028, and broader rollout from 2029.

My first reaction was that this felt like a workplace pensions story, not an advice story. It largely still is. The framework is aimed at scheme operators, trustees, independent governance committees and employers, not at individual advice recommendations. But the more conversations I’ve had about it, the more I think the information it eventually produces is worth advisers keeping an eye on.

CP26/25: The Value for Money Framework: consultation

Why this might still matter to advisers

Cost has always been a relatively easy thing to justify in a suitability report. It’s a number. Either the charges are competitive or they’re not, and that’s simple to evidence. Value is a different kind of judgement, made up of things that are harder to reduce to a single figure: how a scheme’s investments have actually performed, how responsive the provider is, whether members get the support they need when something goes wrong.

The framework is not an adviser suitability rule, and it does not automatically mean a scheme with a weaker rating is unsuitable for an individual client. But once more comparable value information exists across workplace schemes, it may become another piece of evidence firms need to consider and interpret, particularly where a workplace or legacy arrangement forms part of a wider recommendation.

That’s the interesting part, for me. Not a new rule, but a new source of evidence that didn’t really exist in this form before.

What’s worth doing now

• Start noting the reasoning behind scheme and provider recommendations in more than cost terms, even informally, so there’s a trail to point back to later.
• If your firm runs a centralised retirement or investment proposition, take a proper look at how each element would hold up against cost, performance and service, not cost alone.
• Keep half an eye on how the framework’s ratings actually get published as it rolls out from 2028 onward. A scheme that looks fine today could be rated differently once the comparisons exist.
• Consider how your research and review processes would use future published value assessments where a client’s workplace or legacy arrangement is relevant to the advice.

None of this is about second-guessing recommendations that have already been made, or assuming every legacy scheme needs revisiting because of this consultation. It’s about building the habit of capturing why a scheme was considered good value at the time, so that reasoning is there if it’s ever needed.

The framework is primarily a workplace pensions reform, still some years from full rollout. But the information it creates could eventually influence research, review processes and the way firms evidence decisions involving existing workplace arrangements, even without becoming a suitability rule in its own right.

As these value ratings start to appear over the next few years, what would you want to see change first in how your firm researches workplace schemes?

If you’d like to learn more about how we support financial planning firms with suitability consulting, annual reviews and operational support, you’ll find more information here:

Services

A while back, I wrote about how every firm we work with seems to run its annual review process slightly differently. The same consultation proposing changes to what counts as sufficient information (see last week’s issue) is also proposing that firms should instead offer periodic reviews at a frequency reflecting the client’s needs, rather than a fixed annual one.

On paper, that sounds like flexibility. In practice, it’s a new decision a firm now has to make, and be able to explain.

Why “periodic” is harder than “annual”

An annual review has one big advantage: nobody has to think about it very hard. The date comes round, the review happens. It isn’t necessarily the right cadence for every client, but it’s simple, and it’s consistent.

Periodic reviews remove that simplicity. If the frequency is meant to reflect the client’s actual circumstances, someone has to decide what those circumstances call for, and then be able to explain why. A client in drawdown, relying on the portfolio for income, probably needs checking in on more often than someone twenty years from retirement with a straightforward pension. That much is obvious. What’s less obvious is how a firm decides, consistently, where every other client sits in between.

And once that decision exists, it needs the same discipline the annual review used to get automatically. If a client goes eighteen months between reviews instead of twelve, was that decided deliberately, based on their situation, or did it just happen because nobody flagged it?

What’s worth thinking about now

• Look at how review frequency actually gets decided today. Is it genuinely need-based already, or has “annual” been doing the thinking for you?
• Build some simple criteria for what pushes a client toward more frequent reviews. Drawdown, vulnerability, recent life changes and volatile portfolios are the obvious starting points.
• Document the reasoning per client, not just the date. “Reviewed every 12 months” and “reviewed every 12 months because of X” are very different things to show a regulator, or a new adviser picking up the file.
• Think about capacity. If review frequency becomes genuinely variable across the client bank, the servicing model behind it needs to flex with it too, not just the calendar.
• Check that the service agreement, client communications and charging structure still accurately describe what the client will receive.

That last point is one we spend a lot of time on with firms, if I’m honest. It’s rarely the review itself that’s the hard part. It’s building a servicing model, and a fee structure, flexible enough to support reviews that don’t all happen on the same twelve-month clock, without the whole operation losing its shape.

The FCA moving away from a fixed annual requirement doesn’t remove the need for a review process. It just moves the hard part earlier, from running the review to deciding when one’s actually needed. Firms who’ve never had to make that call before are about to need a reason for one.

What’s your process today for deciding when a client is due a review, and where would that reasoning live if someone asked to see it?

If you’d like to learn more about how we support financial planning firms with suitability consulting, annual reviews and operational support, you’ll find more information here:

Suitability Report Writing Services for Financial Advisers