It’s not surprising that there’s a lot of confusion about suitability reports. Once you know where to look in the FCA Handbook, the FCA’s requirements for suitability reports are, in reality, relatively concise. Yet over time, reports have grown far longer and more complex – less as a result of direct regulatory demand, and more through layers of industry interpretation and a collective desire to ‘play it safe’. Throw in the influence of Financial Ombudsman Service decisions and their implications for suitability reports, and things start to feel quite complicated.

This can lead to 60-page suitability reports, including everything from the client’s personal circumstances, to critical yield information, to output from your pension switch comparison software of choice.

On the surface, this approach might feel like it’s reducing the risk of being called out by the FCA or a file checker – but in reality, it can leave the client swamped by information and unsure of what they’re actually agreeing to. It also means that the paraplanner’s focus is split across so many areas that the really crucial bits – the parts the FCA say must be included in a suitability report – don’t receive the attention they deserve, and can be treated as an afterthought rather than one of the main building blocks of a good suitability report.

This blog gets back to basics, with a focus on what definitely needs to be included in a suitability report. These are the areas that can make or break a good (and FCA compliant) suitability report.

Suitability Report Essentials – According to the FCA

In COBS 9.4, the FCA states that a suitability report must:

• Confirm the client’s demands and needs (i.e. their objectives)

• Explain why the recommendation is suitable for the client

• Explain any possible disadvantages of the recommendation

This has been extended slightly for MiFID business in COBS 9A.3.3, but mainly covers the points above. It also adds that the suitability report must:

• Include information on whether the recommendation is likely to require the client to seek a regular review

COBS9A.3.4 then goes on to remind us to ensure that the report is ‘clear, fair and not misleading’.

For pension recommendations, there are two other points to consider: stakeholder pensions and workplace pensions.

This can be quite hard to believe when you’re used to working with very long suitability reports, but that is a summary of what the FCA rules say must be in a suitability report. I believe that much of the extra material that has become standard in many suitability reports has come from the ‘assessing suitability’ section of COBS, which covers the research needed on file – but not necessarily in the report.

Assessing Suitability

This is covered by COBS 9.2 and COBS9A.2, and for most firms with a robust fact finding and information gathering process, this section should be covered by your files – so there is no need to put this information in the report. A part that’s worth looking at more closely in the context of suitability reports is the guidance on replacement business (covered by COBS 9A.2.18 & COBS 9A.2.18A).

This section covers the FCA’s guidance on the comparisons that need to be done when recommending a client switches to a new provider. This is for the file and does not necessarily need to go into the suitability report unless it helps the client understand something, helps explain why the recommendation meets their objectives, or is linked to a disadvantage.

The FCA leaves it to you to decide which comparisons you actually do, and they don’t say it needs to go into the report. Their guidance states that “a firm must collect the necessary information on the client’s existing investments and the recommended new investments and undertake an analysis of the costs and benefits of the switch, such that they are reasonably able to demonstrate that the benefits of switching are greater than the costs.” Notably, this doesn’t just mean a numerical comparison of charges – it includes other non-numerical costs or benefits that might be relevant to the client, such as the flexibility on offer, the investments available, or other ways the plan might help the client achieve their objectives.

Consumer Duty

The existing ‘clear, fair and not misleading’ guidance was taken to another level by Consumer Duty, with its ‘Consumer Understanding’ outcome, and is detailed in ‘PRIN 2A.5 Consumer Duty: retail customer outcome on consumer understanding’. This part of the Handbook states that you must “provide relevant information with an appropriate level of detail, to avoid providing too much information such that it may prevent retail customers from making effective decisions.”

Take a critical look at your suitability report templates and whether they’re helping clients make informed decisions. If you’ve got feedback from clients that they don’t read them, this is a red flag that they could be too long or difficult to understand.

This is also echoed by the way the FOS assess complaints. Lack of client understanding or things not being clear are common themes.

Conclusion

Ultimately, a good suitability report is about clearly explaining to the client what you are recommending, why it meets their objectives, and what the potential downsides are.

There will always be a place for detailed analysis, comparisons and supporting evidence – but much of this belongs on file, not in front of the client. By focusing on what the FCA actually requires, and using judgement about what genuinely helps the client understand the recommendation, firms can produce reports that are both compliant and meaningful.

In many cases, less really can be more.

War, Energy, and the New Fragility in Supply Chains

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

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

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

High Turnover Strategies – A Contrarian Defence?

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

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

TIME:Advance – A Case Study in Investor Confidence

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

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

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

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

Market Movers

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

Practical Takeaways for Advisers

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

Final Word

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

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

– Paul

If you’ve glanced at the Spring Statement headlines and thought, “that was fairly uneventful”… you’re not wrong.

No big tax shocks. No sweeping reforms. Nothing that immediately forces a rethink of advice strategies overnight.

But that doesn’t mean nothing’s changed.

In fact, from what we’re seeing across firms this week, it’s the opposite. The calm headline is masking a lot of underlying movement. New allowances, frozen thresholds, and small rule changes are all stacking up into something advisers are going to be talking about with clients for the next few months.

And with the new tax year landing right as everyone switches off for Easter, there’s a bit of a strange gap between “change has happened” and “we’ll deal with it next week”.

So this felt like a good moment to pause and look forward, not back.

What’s actually changing this tax year?

A few key updates are worth having on your radar:

• ISA allowance remains at £20,000. No change, but still one of the simplest and most underused planning tools in some client segments.

• Dividend allowance at £500. Now low enough that more clients are drifting into tax without realising it.
• Capital Gains Tax allowance stays at £3,000.  Which continues to pull more everyday investors into CGT conversations.

• Income tax thresholds still frozen.  Which quietly increases tax over time, especially for clients with growing income or withdrawals.

• Pension allowances remain largely stable. But the ongoing conversations around pensions and lifetime planning aren’t going anywhere.

And Neil Jones’ piece in Money Marketing captures the tone well, a calm statement on the surface, but a busy year underneath:

Neil Jones: Spring Statement calm hides busy tax year ahead

What we’re hearing from firms

This week has been interesting.

There’s been a noticeable uptick in conversations around:

• Reviewing CIPs and CRPs

• Sense-checking existing client strategies

• Updating templates and assumptions

• Rechecking income, dividend, and CGT positioning

Not because anything dramatic has happened.

But because when you layer these small changes together, they start to shift the shape of advice.

And advisers know that.

It’s less about reacting to one big rule change, and more about asking:

“Does what we’re already doing still land in the right place?”

The bit that tends to get missed

The technical updates themselves aren’t usually the hard part.

It’s what happens next.

Because this is the time of year where a lot of firms fall into one of two traps:

1. Treating it as a one-off update  Quick review, tweak a few assumptions, move on.

2. Overcomplicating it  Trying to rebuild everything at once, just in case something’s been missed.

In reality, most of the value sits somewhere in the middle.

A more practical way to approach it

From what we’ve seen work well across firms, this kind of tax year shift is best handled as a structured check, not a scramble.

A few simple prompts we’ve been using in conversations this week:

1. Start with your existing advice, not new ideas  Where are clients now drifting into tax unintentionally?  Dividend income and CGT are the obvious ones this year.

2. Revisit your “default” recommendations  Are your standard approaches still as efficient as they were 12 months ago?

3. Sense-check client communication  Are you proactively explaining these changes, or waiting for clients to ask?

4. Look at consistency across advisers  Are teams interpreting the changes in the same way, or slightly differently?

That last one is the one that tends to creep in quietly.

Small regulatory or tax changes don’t just affect outcomes, they affect how consistently advice is being delivered across a firm. And that’s usually where the real work sits.

Why this year feels slightly different

None of these changes are new in isolation.

We’ve had frozen thresholds before. We’ve had allowance reductions before.

But what’s different now is the cumulative effect.

More clients are:

• Crossing into tax thresholds earlier

• Triggering CGT events more frequently

• Holding assets that need more active management

• Asking more questions about “why this, not that?”

Which means suitability conversations naturally become a bit more detailed.

Not more complicated, just… less assumptive.

And that’s where a lot of firms are focusing their energy right now, making sure the logic behind advice is still clear, consistent, and easy to evidence if needed.

That shift towards clarity and consistency is something we see every day in the work we do

One final thought before the long weekend

This probably isn’t something anyone’s rushing to deal with today.

And that’s fine.

But when things pick back up next week, this is likely to be where a lot of client conversations start.

Not with big, dramatic changes.

Just with small nudges that need explaining properly.

Because for clients, it’s rarely about the allowance itself.

It’s about understanding what it means for them.

There’s a moment most advisers have had.

You send something important to a client, maybe a recommendation, maybe documents, maybe something time-sensitive.

And then, just for a second, you hesitate.

Did that go to the right person? What if they forward it? What if it gets intercepted?

We don’t always say it out loud, but there’s a quiet discomfort with how much of the advice process still runs through email.

And the reality is, that discomfort is justified.

Email isn’t just outdated, it’s exposed

We’ve got used to email because it’s easy. It’s familiar. Everyone has it.

But from a risk perspective, it’s doing a lot of heavy lifting it was never designed for.

The latest Cyber Security Breaches Survey 2025 makes that pretty clear. Phishing alone now affects 85% of businesses, making it the most common and disruptive type of cyber attack

If you want to dig into the findings, the UK Government summary is worth a read:

Cyber security breaches survey 2025

And this isn’t just the obvious scams anymore.

Attacks are:

• Targeted
• Personalised
• Often indistinguishable from legitimate communication

Some even use AI to mimic tone, writing style, and context.

Which means the weak point isn’t always your systems.

It’s your communication layer.

Why this matters more for advice firms

In most industries, a dodgy email is annoying.

In financial advice, it’s something else entirely.

You’re dealing with:

• Sensitive personal data
• Investment instructions
• Life savings, pensions, inheritances

If something goes wrong, it’s not just an IT issue. It’s:

• A client trust issue
• A regulatory issue

The FCA has been increasingly clear on operational resilience and protecting client data as part of good outcomes under Consumer Duty: https://www.fca.org.uk/firms/consumer-duty

And once that trust is shaken, it’s incredibly hard to rebuild.

The uncomfortable truth

Most firms haven’t consciously chosen email as their primary communication tool.

It’s just… what’s always been there.

But when you step back, it creates a few problems:

• No real control once it’s sent
• No guaranteed identity verification
• No consistent audit trail across conversations
• Heavy reliance on clients spotting red flags themselves

That last one is the bit that should make everyone pause.

Because we’re effectively asking clients to be part of our security framework.

What better looks like (in practice)

This isn’t about throwing everything out and starting again.

It’s about being more deliberate with how client communication is handled.

We’re seeing a shift towards more secure, controlled environments.

1. Moving sensitive communication off email

Not everything needs to leave your ecosystem.

Client portals and secure messaging platforms create:

• Controlled access
• Verified identities
• A consistent communication history

For example, this piece on Plannr’s mobile app shows how platforms are evolving to centralise and secure client interaction: https://professionalparaplanner.co.uk/plannr-technologies-launches-mobile-app/

2. Rebuilding trust through clarity, not just security

Security isn’t just technical.

It’s also about how things feel to the client.

If a client receives:

• A branded notification
• From a platform they recognise
• In a consistent format

They’re far more likely to trust it, and less likely to fall for something that sits outside that pattern.

There’s also a broader industry push towards improving digital communication standards, something covered well here: https://www.ftadviser.com/your-industry/2024/02/06/how-advisers-can-improve-client-communication/

3. Treating communication as part of your advice process

This is the big one.

Communication isn’t just admin. It’s part of suitability.

If a client misunderstands something because:

• It was buried in an email chain
• Sent as an attachment they didn’t open
• Or mixed in with five other threads

That’s not just inconvenient.

It can affect outcomes.

A quick sense-check for your firm

If you’re not sure where you stand, these are worth asking:

• Would we be comfortable if every client email we send was intercepted?
• Could we prove exactly what a client has seen and acknowledged?
• Are we relying on clients to identify suspicious messages themselves?
• Do our communication tools reflect the value and sensitivity of the advice we give?

If any of those feel a bit uneasy, you’re not alone.

This isn’t about fear, it’s about maturity

Cyber risk isn’t new.

What’s changed is the level of sophistication and the expectation around how firms respond to it.

We’re also seeing a shift in how businesses think about it internally.

The survey highlights increasing adoption of things like:

• Cyber risk assessments
• Formal security policies
• Business continuity planning

But interestingly, only a relatively small proportion of firms consider cyber risk deeply when choosing new software

Which probably explains why communication is still lagging behind.

Final thought

Most advice firms spend a lot of time refining:

• Investment strategies
• Suitability reports
• Client journeys

But the way those things are actually delivered to clients often hasn’t kept up.

And that gap is where risk creep in.

Research & Due Diligence for Financial Advisers

We provide investment research and due diligence support for financial advisers, helping firms build clear, evidence-based frameworks that strengthen their advice process and support good client outcomes.

Our work sits at the core of your advice proposition, ensuring your Central Investment Proposition (CIP), Central Retirement Proposition (CRP), platform selection and portfolio approach are clearly defined, consistently applied and fully aligned to regulatory expectations.

Investment Research and Due Diligence Approach

We support firms in creating and maintaining a robust, well-documented approach to investment research and due diligence. This includes defining how products, platforms and portfolios are selected, assessed and reviewed, ensuring your advice process is both repeatable and defensible.

Our approach provides clarity and consistency across your firm, giving advisers confidence that recommendations are supported by a structured and well-governed framework.

What We Support

• Central Investment Proposition (CIP) creation and review
• Central Retirement Proposition (CRP) development
• Platform due diligence and comparison
• Portfolio and DFM research
• Target market and client segmentation
• Value for money assessments
• Ongoing monitoring and governance frameworks

Aligned to Consumer Duty and PROD

Our research and due diligence work is designed to support financial advisers in evidencing good client outcomes in line with Consumer Duty and PROD requirements.

We help you demonstrate that your propositions are designed with a clear target market, deliver fair value and are supported by appropriate governance and oversight across your advice process.

Supporting Your Investment & Advice Framework

We work closely with firms to ensure their investment philosophy and advice framework are clearly defined and consistently applied. This includes evidencing your approach to platform selection, investment strategy, ESG considerations and the use of in-house or outsourced investment solutions.

Our goal is to ensure your documentation reflects how your firm actually operates, creating a practical framework that supports advisers in delivering consistent, high-quality advice.

Independent Research & Evidence

All recommendations and frameworks are supported by structured, independent investment research and due diligence. We use recognised research tools and methodologies to ensure your propositions are robust, evidence-based and aligned to current market conditions.

This provides a clear audit trail and strengthens your ability to demonstrate the rationale behind your advice process.

Value for Money & Ongoing Oversight

Value for money is a key component of our research and due diligence process. We support firms in assessing whether platforms, portfolios and investment solutions remain appropriate for their target market and continue to deliver fair value over time.

We also help establish ongoing review and monitoring processes, ensuring your proposition evolves in line with market changes, regulatory expectations and client needs.

Why Financial Advisers Choose Us

Financial advisers choose our research and due diligence support because we combine technical expertise with a practical understanding of how advice businesses operate. We create documentation and frameworks that are clear, usable and tailored to your firm.

Rather than generic templates, our work reflects your processes, philosophy and client base, helping you maintain consistency while retaining flexibility in how you deliver advice.

Connected Advice Support

Our research and due diligence service forms part of our wider support for financial advisers, working alongside paraplanning, suitability report writing and operational support to strengthen your overall advice process.

• Outsourced paraplanning services
• Suitability report writing services
• Suitability consulting and support

If you are looking to strengthen your investment research and due diligence approach, we provide the structure, clarity and expertise to support long-term, consistent advice delivery.

I nearly didn’t write this one.

Not because there’s nothing going on. Quite the opposite.

There’s loads happening… but none of it in a way that’s easy to explain.

Rates haven’t moved when people thought they would. Markets are reacting, but not always how you’d expect. And depending on which article you read, the outlook is either cautiously optimistic or quietly concerning.

That’s the reality most advisers are sitting in right now.

Not chaos. Not clarity. Just that slightly uncomfortable middle ground where clients still expect answers.

The calm that isn’t really calm

The Bank of England holding rates at 5.25% might look like stability on the surface.

But it doesn’t feel like stability when you’re sat in front of a client.

Because expectations had already shifted. Clients were primed for change. And now you’re explaining why nothing happening… still matters.

Bank of England votes unanimously to leave rates unchanged at 3.75%

That gap between expectation and reality is where advice gets harder.

You’re not just explaining events. You’re explaining the absence of them.

Capital is moving, just not where clients expect

While rates are standing still, capital definitely isn’t.

The £112bn ETF provider acquiring a UK alternatives manager is a good example.

The bestselling fund houses of 2025 revealed

This isn’t just industry noise.

It points to something we’re seeing more of in actual cases:

• A continued push towards alternatives
• More pressure to justify diversification decisions
• Institutions repositioning earlier than retail

We’re not seeing a sudden rush into alternatives.

But we are seeing more conversations about them. And more importantly, more scrutiny when they show up in a recommendation.

Or when they don’t.

The UK question keeps coming up

Then there’s the UK.

International investment into UK businesses is down significantly since 2021.

International investment into UK businesses down a third since 2021

That filters through quicker than people think.

It shows up in client conversations like:

“Should we still be overweight UK?” “Is this an opportunity or a warning sign?”

And the honest answer most of the time is… it depends.

Which isn’t always what clients want to hear.

So again, the pressure lands on how well the advice is explained and evidenced, not just what the decision is.

At the same time, the outlook isn’t exactly negative

It would be easy to read all of that and assume the tone is pessimistic.

It isn’t.

HSBC’s latest outlook talks about “changing narratives” but still points to continued opportunity.

HSBC Private Bank shares Q2 2026 investment outlook: changing narratives, continued opportunity

That feels about right.

Most advisers I speak to aren’t bearish. They’re not overly optimistic either.

They’re just… navigating.

What this actually means in practice

This is the bit that matters.

Because none of your clients are asking for a market summary. They’re asking whether what they have still makes sense.

And right now, that’s harder to answer cleanly.

A few things we’re seeing across firms:

Explanations are getting longer

Not because anyone wants them to be.

But because you’re having to explain:

• Why rates haven’t moved
• Why portfolios haven’t reacted how clients expected
• Why staying put is sometimes the right call

You can feel when an explanation is doing too much heavy lifting.

That’s usually a sign something underneath it isn’t clear enough.

Justification is under more pressure

Especially around:

• Asset allocation
• Use of alternatives
• UK vs global exposure

“Because it’s reasonable” doesn’t really cut it anymore.

It needs to be evidenced. And it needs to hold up if someone else picks the file up cold.

That’s where we see the strain.

Consistency matters more than being right

Clients are consuming information from everywhere now.

News. Social. WhatsApp groups. Headlines taken out of context.

So if your narrative shifts too often, even for good reasons, it can start to feel like uncertainty.

Consistency builds confidence. But only if it’s backed by clear logic.

Not templates. Not filler wording. Actual thinking.

A quick sense check

If the last couple of weeks have felt a bit harder than usual, it’s probably not just you.

It might be worth stepping back and asking:

• Could someone else pick up this case and understand the decision path straight away?
• Are we showing the reasoning, or just describing the outcome?
• Would this still make sense in six months if markets move again?

Because this is where advice either holds up… or quietly starts to unravel.

Not in extreme markets.

In these slightly awkward ones where nothing is clearly wrong, but nothing feels particularly settled either.

Final thought

Months like this don’t look dramatic from the outside.

But they’re where the real work happens.

No big market moves to point at. No easy narrative to lean on.

Just clients looking for reassurance that what they’ve got still makes sense.

And that doesn’t come from reacting quickly.

It comes from being able to explain, clearly and confidently, why the advice stands up in the first place.

If this feels familiar, or you’re seeing the same conversations play out in your firm, we’d be interested to hear how you’re approaching it.

Outsourcing has quietly become normal in financial planning.

Paraplanning, administration, compliance support, portfolio management. Lots of firms now rely on specialist partners across different parts of the advice process.

And to be clear, that can work brilliantly.

Running an advice business today means juggling client work, regulation and a lot of operational pressure. Having people who specialise in certain parts of the process can make firms more efficient and often improve the quality of the work.

But it does raise a question firms are starting to think about more carefully.

If parts of the advice process sit outside the firm, how confident are we about the governance around those stages of the work?

Suitability is rarely one step

Suitability isn’t one task.

It’s the end result of a chain of work that happens behind the scenes.

Factfinding. Research. Analysis. Suitability report drafting. Compliance review.

Each step feeds into the final recommendation that goes to the client.

Increasingly, parts of that chain might involve external partners. A paraplanner working remotely. A compliance team reviewing files. Portfolio management sitting elsewhere.

None of that is necessarily a problem. In many cases it improves efficiency and brings in expertise.

But it does mean the advice process is often more spread out than it used to be.

Responsibility still sits with the firm

The FCA has always been very clear on outsourcing.

Firms can outsource activities. They cannot outsource responsibility.

If a third party is involved in the advice process, the firm is still accountable for the oversight of that relationship.

And when you think about the type of information involved in suitability work, that matters.

Advice files contain some of the most sensitive information in a client’s financial life. Fact finds reveal personal circumstances. Platform data shows investment holdings. Suitability reports document complex financial decisions.

If those files move through different systems or organisations along the way, firms need confidence that the same standards apply throughout.

The operational side of suitability

Historically, most conversations about suitability focus on the recommendation itself.

Was the advice appropriate? Was the research robust? Does the report explain the reasoning clearly?

All important questions.

But suitability is also supported by the operational process behind the scenes.

How information is handled. How files move between people. Who can access them. What controls sit around that process.

Good governance behind the scenes helps make sure the final recommendation rests on a process that is consistent and reliable.

Practical checks firms can make

For firms that rely on outsourced support, the real question isn’t whether outsourcing is right or wrong. In many cases it’s simply how modern advice firms operate.

The more useful question is whether the right checks sit behind those relationships.

A few areas are worth paying attention to.

Information security

Advice files contain highly sensitive personal and financial data. Firms should understand how providers store, transfer and protect that information, and whether recognised frameworks such as ISO 27001 are in place.

Operational resilience

If systems fail or a provider experiences disruption, how quickly can normal service resume? Providers should have clear processes for continuity and recovery.

Governance and oversight

External partners should operate with clear processes and documented controls. Firms should be able to demonstrate that they have assessed those arrangements properly.

None of this is about adding bureaucracy for the sake of it. It’s about making sure the advice process works safely and consistently.

Suitability depends on the whole process

Encouragingly, governance standards across the profession are improving.

More firms are taking a structured approach to assessing the organisations involved in their advice process. Compliance teams and boards are asking better questions about operational resilience, data protection and governance frameworks.

That reflects a broader shift in the profession.

Suitability isn’t just about the recommendation at the end of the process.

It depends on the strength of everything that sits behind it.

And as the advice supply chain expands, those foundations become more important than ever.

Because while parts of the advice process may be outsourced, responsibility never is.

If you work anywhere near financial advice, you’ll know the feeling.

You open your inbox, skim a few FCA updates, and immediately wonder whether you should make a coffee first… or lie down.

Regulation rarely arrives in one neat package. It tends to come in waves. A blog here, a consultation there, a press release about something that initially feels unrelated, until you realise it probably isn’t.

Over the past couple of weeks there have been a few developments worth keeping on the radar. None of them radically change how advice works overnight, but together they say quite a lot about the direction the regulator is heading.

And, as paraplanners, advisers and advice teams, that direction matters.

Targeted support: a new middle ground

One of the more interesting announcements is that firms can now apply for permission to provide targeted support.

This is part of the FCA’s ongoing work to address the so-called “advice gap”. The reality is that millions of people need some level of guidance but won’t necessarily engage with full regulated advice.

Targeted support sits somewhere in the middle. Not generic guidance. Not full personal advice either. Instead, it allows firms to provide suggestions based on specific customer characteristics, without needing the full advice process.

On paper, that sounds sensible. In practice, it raises some fairly big questions.

Where exactly is the line between targeted support and advice?

How much data do you need before making a suggestion?

And perhaps most importantly, how do you evidence that what you’ve done still delivers good outcomes?

From a paraplanning perspective, this will likely create more conversations internally. If firms start offering targeted support models, someone still needs to think carefully about the logic behind those recommendations and how they are documented.

Consumer Duty hasn’t gone anywhere, and the regulator will expect firms to evidence the reasoning behind their approach.

So although this initiative is designed to broaden access to help, it won’t necessarily make life simpler from a governance point of view.

The influencer fines (yes, really)

Another headline that caught a lot of attention recently was the FCA fining several social media influencers for promoting financial products without proper authorisation.

For most regulated advice firms, this might feel like it belongs to a completely different world. We’re used to compliance approvals, clear financial promotions processes, and careful wording.

But this story highlights something bigger.

Financial promotions rules apply regardless of platform. Instagram, TikTok, YouTube, LinkedIn… the regulator doesn’t really care where the content appears. The same standards apply.

In a strange way, it’s a reminder of how structured the advice profession actually is.

Most advice firms have robust sign-off processes for marketing, promotions, and client communications. It can feel frustrating sometimes when wording gets debated endlessly, but the alternative is the Wild West.

And that rarely ends well.

Fair value still means what it says

The FCA also published a blog clarifying what it means when it talks about fair value.

If you’ve spent any time dealing with Consumer Duty implementation, you’ll know this phrase has become a regular part of the industry vocabulary.

But the FCA’s message was essentially this: fair value isn’t just about price.

It’s about the overall relationship between cost and benefit.

That includes things like:

• product design • charges and fees • customer support • distribution channels • and whether the product actually meets the needs of the target market

For advisers and paraplanners, this isn’t entirely new thinking. Suitability assessments have always required a holistic view.

But the FCA is clearly reinforcing that firms need to demonstrate how value is delivered, not simply assume it.

Which, in practical terms, means documentation matters. The reasoning behind recommendations matters. The audit trail matters.

In other words, the same things that good advice teams have been quietly focusing on for years.

Credit file gaps and borrower visibility

One slightly less discussed update relates to proposals aimed at closing gaps in borrowers’ credit files.

The FCA is exploring ways to improve how information about consumer borrowing is reported and shared between credit reference agencies.

At first glance, this might feel more relevant to lenders than advisers.

But for anyone involved in holistic financial planning, it’s a reminder of how important accurate client data really is.

When advisers assess affordability, debt management, or mortgage strategy, they rely on the information available.

If that information is incomplete, the advice framework becomes harder to build with confidence.

Better credit reporting might sound technical, but the real goal is simple. More accurate data leads to better decisions.

What this all says about the direction of travel

None of these developments, taken individually, will transform advice firms overnight.

But collectively they point to a theme that has been consistent for a while now.

The regulator wants three things:

Better outcomes Clearer accountability Stronger evidence

Not necessarily more paperwork. Just better reasoning behind decisions.

For paraplanners and advice teams, that actually aligns quite closely with the work we already do.

A large part of paraplanning has always been about translating client objectives, technical analysis, and regulatory requirements into something coherent and defensible.

In other words, making sure the logic holds together.

Sometimes regulation gets framed as an obstacle. And yes, it can occasionally feel that way.

But when you strip it back, most of the FCA’s direction of travel is simply asking firms to prove that the advice they deliver genuinely serves the client.

Which, if we’re honest, is exactly what most people in this profession were trying to do anyway.

I didn’t expect to spend part of last week reading about orbital junk.

But here we are.

I was working on an ESG-tilted portfolio for a client who’s very focused on environmental innovation. We’d covered the usual ground, renewables, clean tech, battery storage. Then I stumbled across an article about the growing market for space debris removal.

At first I nearly skipped past it. It sounded like something from a Netflix documentary.

But the more I read, the more it felt like one of those themes that quietly moves from “that’s interesting” to “actually, that’s investable”.

So let’s talk about it.

The Problem We Don’t See

There are thousands of pieces of debris orbiting Earth. Old satellites. Fragments from collisions. Objects travelling at speeds that can damage or destroy operational satellites.

And we rely on those satellites more than most clients realise, GPS, communications, weather data, banking infrastructure.

As launches increase, so does congestion risk.

Fortune Business Insights projects steady growth in the space debris monitoring and removal market, driven by both commercial and regulatory pressure:

Global Space Debris Monitoring and Removal Market Growth

Congruence Market Insights makes a similar point, linking growth directly to increased satellite activity:

https://www.congruencemarketinsights.com/report/space-debris-removal-market

In other words, this isn’t just environmental clean-up. It’s infrastructure protection.

And that shifts the conversation.

When a Niche Theme Starts Attracting Serious Capital

What made me pause wasn’t just the environmental angle. It was the capital flow.

There are UK firms actively developing debris tracking and removal technology. Innovation News Network looks at how the UK is addressing the risk:

Mitigating the risks of space debris in the UK

Mewburn highlights some of the UK companies tackling orbital debris commercially:

Saving Space: the UK-based companies tackling orbital debris

And when investment banks start publishing pieces on the expanding space economy, as DelMorgan & Co have done:

Banking on Orbit: Investment Banking’s Expanding Role in the Space Economy

…that’s usually a sign that this is moving beyond a science project.

Still early. Still volatile. But no longer fantasy.

The Practical Bit: How Would a Client Access It?

This is where the paraplanner brain kicks in.

Right now, most retail exposure would be indirect:

• Aerospace and defence stocks

• Thematic space economy ETFs

• Private market funds with space-tech exposure

Neo Market Data outlines some of those routes:

How to invest in space debris cleanup companies

But let’s be honest. Pure-play debris removal companies are limited. Many are early-stage. Revenue visibility is patchy. Volatility is likely.

So the real conversation isn’t “can we invest in this?”

It’s “how does this sit within the client’s overall risk profile and objectives?”

The Bit That Matters: Suitability

Whenever a theme like this pops up, especially one with a strong ESG narrative, it’s easy for enthusiasm to run slightly ahead of structure.

And this is where we have to slow it down.

COBS 9 is clear. We need sufficient information about the client’s knowledge, experience, objectives and financial situation before making a recommendation:

https://www.handbook.fca.org.uk/handbook/COBS/9/2.html

Under Consumer Duty, we’re expected to deliver good outcomes, not just interesting portfolios:

https://www.handbook.fca.org.uk/handbook/PRIN/2A/

So instead of writing:

“Client interested in innovative ESG opportunities.”

We need something more robust:

“Client seeks a small, clearly defined allocation to high-growth, high-volatility infrastructure-linked innovation, with capacity for loss confirmed and time horizon aligned.”

It sounds drier. It is safer. And it’s defensible.

That difference is often where our work really earns its keep.

What I’d Be Asking in Practice

If this theme came up in a client meeting, I’d want clarity on three things:

1. Allocation size

Is this a satellite holding within a diversified portfolio, or is it drifting into concentration risk?

2. Time horizon

Are we genuinely thinking long term, or reacting to a headline?

3. Downside understanding

If this underperforms for five years, is the client still comfortable?

Because thematic investing isn’t the issue. Unframed thematic investing is.

Final Thoughts

Space debris removal is unlikely to be a core portfolio holding any time soon.

But it’s a useful reminder of how quickly new themes can move from obscure to investable, especially when infrastructure, regulation and capital markets all start pointing in the same direction.

Our role, as paraplanners and suitability professionals, isn’t to dismiss new ideas.

It’s to slow them down. Structure them properly. Evidence them clearly.

That’s where the real value sits.

If this mirrors conversations you’re having in your firm, I’d be genuinely interested to hear how you’re approaching niche themes like this.

Global Space Debris Removal Market

Space Debris Monitoring & Removal Market

How to invest in space debris cleanup companies

Mitigating the risks of space debris in the UK

Saving Space: the UK-based companies tackling orbital debris

Banking on Orbit: Investment Banking’s Expanding Role in the Space Economy

A couple of weeks ago, I was on a call with a firm that had finally taken the plunge.

They’d moved off a very old, very clunky back-office system. The kind that had been “about to be replaced” for years but somehow kept surviving.

They’d switched to one of the big hitters. Proper infrastructure. Cleaner workflows. The sort of platform most advisers recognise instantly.

You could hear the relief.

“No more spreadsheets on top of the CRM.” and “No more double keying.”

Then one of the advisers laughed and said:

“It’s fancy… but I think we’re still doing things the old way inside it.”

That’s the bit that I’ve been replaying in my head.

Because upgrading technology is a big step. But it doesn’t automatically upgrade behaviour across the team. And a CRM isn’t just used by one person.

It’s touched by advisers, paraplanners, compliance, admin teams. One case can pass through five, maybe six pairs of hands before it’s finished.

If everyone has a slightly different understanding of what “complete” looks like, or what good documentation means, the system will simply reflect that.

The platform might be modern. The habits inside it might not be.

Integration is helpful. It isn’t the answer.

There’s been a lot of focus recently on integration and streamlining.

Money Marketing covered the Intelliflo and Söderberg partnership, aimed at simplifying adviser technology.

Intelliflo and Söderberg team up to streamline adviser technology

Dynamic Planner has also talked about unlocking trusted advice through stronger data and infrastructure.

Dynamic Planner sets out vision to unlock trusted advice

And there’s been a clear message across the trade press that data needs to sit at the centre of business strategy.

Why data must be at the centre of business strategy

All of that makes sense. But integration does not automatically create consistency.

If objectives are written differently adviser to adviser, the new system will store that difference more neatly. If suitability rationale varies wildly, the CRM will faithfully record that variation.

Technology is brilliant at amplifying whatever is already there. That includes inconsistency.

Why digital projects wobble

IFA Magazine recently explored why digital transformation fails.

How to ensure your digital transformation doesn’t fail

In my experience, it’s rarely because the software is poor. It’s usually because firms assume the system will create discipline.

Spoiler alert, It won’t. Discipline has to be agreed first.

Before you automate anything, you need clarity on:

• What good advice looks like in your firm
• How objectives should be articulated
• What a strong rationale includes
• What must be evidenced before a case moves forward

Otherwise you end up with a very modern system running very old habits.

And that’s when the excitement of “new tech” quietly fades.

Consolidation changes the lens

At the same time, consolidation and the great wealth transfer are shaping the market.

The great wealth transfer, women & wealth and consolidation – key adviser trends that will define 2026

Defaqto’s recent platform review is another reminder of how quickly the landscape is shifting.

Defaqto reveals the recommended platforms that dominated last year

But here’s what I think often gets underestimated.

When firms merge, acquire, or prepare for sale, the question isn’t just “Which CRM do you use?”

It’s “How consistently do you use it?”

Because when ten different people touch a case, variation creeps in easily.

Different wording. Different levels of detail. Different interpretations of what “ready” means.

Under due diligence, that becomes visible very quickly. Buyers and consolidators are not looking for the shiniest system.

They’re looking for shared standards.

They want to see that regardless of which adviser handled the case, or which paraplanner drafted it, the structure and evidencing are consistent.

If that consistency isn’t there, it shows. And that’s not a tech issue. It’s a team alignment issue.

What “data at the centre” really means

When people say data needs to sit at the centre of strategy, it can sound quite grand. In reality, it’s simple. It means being able to answer ordinary questions confidently:

• How often do objectives change late in the process?
• Where does rework usually happen?
• Are discussions documented consistently?
• Can you see behavioural patterns across advisers?

Most firms have the data somewhere. Very few can see it clearly enough to act on it. There’s a big difference between collecting information and being able to rely on it.

Three simple exercises to try

If you’ve upgraded recently, or you’re planning to, here are three things worth doing before the next system review.

1. Compare 10 cases. Read only the objectives section. Do they follow a clear internal structure, or does each adviser phrase them differently?

2. List your non-negotiables. What are the 10 points that absolutely must be right for advice to be suitable in your firm? Are they structured? Validated? Consistent?

3. Separate speed from safety. For each tool you use, ask: Does this make us faster? Does this make us safer?

They are not the same thing.

Speed feels productive. Safety feels slower, but it’s what regulators, insurers, and future buyers care about.

Switching from an outdated system to a modern platform is absolutely the right move.

It reduces friction. It removes duplication. It gives you proper infrastructure. But the real upgrade isn’t the software. It’s the standards your team applies inside it.

Because heading into 2026, the firms that will feel most confident won’t just be the ones with the best integrations. They’ll be the ones with the clearest internal definition of what good advice looks like, and data clean enough to evidence it.

If this resonates with what you’re seeing in your own firm, I’d genuinely love to hear your experience.