Technology

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

Just some Friday musings from me Amy North

Over the last few weeks, we’ve been recruiting at We Complement.

If you’ve been following us on LinkedIn, you’ll probably have seen a few of the posts.

What you probably haven’t seen is the number of conversations we’ve had behind the scenes.

And honestly, they’ve been one of my favourite parts of the whole process.

We’re not really formal interview people.

Of course, we need to understand someone’s experience and whether they can do the role, but if you’ve had a chat with me and Paul Kenworthy over the last few weeks, you’ll know I’m far more interested in hearing your story.

How did you end up in financial services?

How did you find your way into this profession?

What do you enjoy most?

What would you change if you could?

I’ve probably spent more time talking about careers, children, hobbies and life than I have asking interview questions.

One thing kept coming up.

Hardly anybody actually planned to end up here.

Almost everyone just… found it.

That made me smile because when I thought about our own team, exactly the same thing had happened.

Lucy originally studied Film and TV Production. She imagined a completely different career before deciding she wanted the stability of a regular office job. Today, one of her favourite parts of the role is writing suitability reports because it lets her combine technical research with something she’s always loved, writing.

Claire started out in pension administration before gradually moving into a more technical role. She talks about enjoying “putting the puzzle pieces together” to build a solution for clients, which perfectly sums up the way she approaches every case.

Hannah? She’ll quite happily admit she only ended up in financial services because a recruiter found her CV. Now she gets genuine satisfaction from taking one of those files where you wonder where on earth to start and turning it into something clear, well-structured and meaningful for the client.

Different backgrounds.

Different journeys.

The same profession.

One thing I loved was that no two stories were the same.

Some started in pensions.

Some came through administration.

Some had worked in compliance.

One had studied Film and TV.

Nobody followed the same path.

Yet somehow they all ended up in the same profession.

The people we’ve spoken to over the last few weeks were no different.

One person had been freelancing exclusively for the same adviser for years.

The relationship worked brilliantly, but she’d reached a point where she wanted the security that comes with being employed. Her adviser simply didn’t want the responsibility and overheads that come with taking on staff.

It reminded me that flexibility looks different depending on where you are in life.

Then we met two brilliant people who’d done the complete opposite.

They’d taken the leap and started their own businesses.

I absolutely loved hearing about it.

It takes confidence to back yourself like that, and I genuinely think it’s brilliant that more people now see that as an option.

They weren’t looking to leave because things weren’t working. They just wanted a little part-time work while they built their client base.

Unfortunately, we couldn’t make that work, which was genuinely disappointing because they really knew their onions.

Then there were the working parents.

The conversations weren’t about salary.

They were about school runs.

Sports days.

School plays.

The inevitable phone call from school because someone’s been sick.

Being able to disappear for an hour in the afternoon without feeling guilty, then picking work back up later that evening.

As a mum of three myself, those conversations really resonated.

What struck me most about all these chats was that very few people were simply chasing a bigger salary.

Some wanted the security that comes with being employed.

Others wanted more flexibility around family life.

A few wanted the freedom to build something of their own.

And quite a few wanted to work somewhere that genuinely values good technical thinking, where they could ask questions, challenge ideas and be part of the advice process rather than simply writing reports at the end.

That last one came up more than once.

It made me realise how much our profession has changed.

When I first came across it, it was often talked about as a stepping stone to becoming an adviser.

I don’t hear that nearly as much anymore.

People are choosing technical careers in financial planning because they genuinely enjoy the work.

They like solving problems.

They enjoy researching.

They take pride in explaining complex recommendations in a way clients can actually understand.

They’re proud of what they do.

And they should be.

Something else I noticed was just how supportive this profession is.

Every single person we spoke to was happy to share their journey.

Some talked openly about mistakes they’d made.

Others shared advice they’d been given early in their careers.

Nobody felt competitive.

Everyone seemed genuinely happy to help the next person coming through.

I think that’s pretty special.

I can’t think of many careers where so many people seem to have found themselves doing something they never planned… and then couldn’t imagine doing anything else.

The last few weeks have reminded me that our profession is in a really good place.

People are backing themselves.

They’re building careers, businesses and lives that work for them.

They’re choosing workplaces that value good thinking, not just quick turnaround times.

And if that’s the direction we’re heading, I think we’re all onto something pretty special.

You don’t need me telling you that there’s lot of noise around AI in advice right now.

FCA testing. Big firm involvement. Oversight, governance, all the right words.

Important, yes.

But most firms aren’t there yet.

They’re still trying to get comfortable with something much simpler…

Their own advice process.

And AI has a habit of exposing that pretty quickly.

The bit that doesn’t get said out loud

Ask a firm how their advice process works, you’ll get a solid answer.

Ask how consistent it is across advisers…

That’s where it gets a bit vague.

Because in reality:

• Two advisers can take completely different routes to the same outcome
• Two paraplanners can justify it in different ways
• Two QA reviewers can score it differently

And it still passes.

We’ve all seen it.

It’s just been… manageable.

Until now.

Why the FCA is leaning into “oversight”

This isn’t about the FCA suddenly getting excited about AI.

It’s about removing wiggle room.

If tech is helping produce advice faster, then firms should be able to:

• Show how decisions were made
• Demonstrate consistency
• Actually evidence suitability, not just describe it

That expectation didn’t start with AI.

Consumer Duty already set that direction.

AI just shines a light on where things don’t quite stack up.

Understanding the advice market: financial advice firms survey 2025

Where things start to slip

We’re seeing versions of this more and more.

An adviser uses AI to sense-check a recommendation.

It comes back well written. Clean. Logical.

They tweak it. Send it through.

Job done.

But when you slow it down:

• The client objective is a bit loose
• The risk discussion could apply to anyone
• The product justification sounds right, but doesn’t quite prove anything

The document looks better.

But the thinking underneath hasn’t really changed.

That’s the bit that matters.

Where most firms actually are

Not behind. Not ahead.

Just… in the middle.

• Trying bits of AI
• Not fully embedding it
• Slightly unsure how comfortable they should be

While still:

• Relying on QA at the end
• Accepting variation between advisers
• Fixing things after they’re written

That’s fine at a certain scale.

It gets harder when everything speeds up.

The shift that actually matters

The firms getting this right aren’t the ones shouting about AI.

They’re the ones tightening what sits underneath it.

Things like:

Making advice logic explicit Not “this feels suitable”, but why, in a way someone else would land in the same place.

Reducing interpretation Less room for “it depends who reviews it”.

Catching things earlier Not waiting until QA to find the gaps.

Taking consistency seriously Because that’s where most of the real risk sits.

This isn’t about being ahead

It’s about not drifting behind your own output.

AI speeds things up.

If your process doesn’t keep up, the gap between what you produce and what you can confidently stand behind gets wider.

Quietly at first.

Then very obvious.

A better question to ask

Instead of: – “Are we using AI properly?”

Try:

• Would we stand behind this advice if someone challenged it line by line?
• Can we explain the logic without leaning on how nicely it’s written?
• Would two different reviewers land in the same place?

If the answer is “depends”, that’s probably where the work is.

Bringing it back to reality

Most firms don’t need an AI strategy deck.

They need a tighter, more consistent advice process.

Because once that’s in place, AI helps.

Without it, it just makes things look better than they actually are.

If this feels familiar, don’t worry, you’re not the only one.

These conversations are happening quietly across a lot of firms right now.

If you’re seeing it too, we’re always up for a chat.

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.

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.

Technology is speeding up. Advice still needs people.

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

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

On paper, it all sounds promising.

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

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

What the recent tech conversation is really about

A few recent pieces have captured this tension well.

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

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

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

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

Taken together, the message is fairly consistent.

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

Where AI genuinely helps in advice firms

Used well, AI can be a useful support layer.

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

• Helping summarise large volumes of information

• Supporting initial research and comparisons

• Spotting gaps or inconsistencies in data

• Reducing time spent on repetitive administrative tasks

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

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

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

That distinction matters.

Why Suitability Consultants are still central, not optional

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

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

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

• When a case sits outside the usual parameters

• When client objectives are unclear or conflicting

• When suitability hinges on judgement rather than rules

• When an adviser needs to talk through the “why”, not just the “what”

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

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

A practical lens firms can apply now

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

Before implementing anything new, ask:

• What part of the advice process is this actually improving

• Does it reduce friction, or just move it somewhere else

• Who is responsible for sense-checking the output

• How does it fit with existing workflows and standards

• What happens when a case does not fit the model

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

Regulation still expects judgement, not just systems

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

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

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

That expectation is not going away.

Getting the balance right

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

They are doing three things well:

• Strengthening their core processes first

• Using technology to support people, not replace them

• Keeping experienced Suitability Consultants closely involved

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

Final thoughts

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

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

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

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

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

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

What stood out to us this year

Paul Kenworthy

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

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

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

Hannah Keane

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

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

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

Nicola Porter

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

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

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

Lucy Wylde

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

Claire Robertson DipPFS Certs CII (MP/ER)

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

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

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

The bigger picture

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

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

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

Looking ahead, quietly

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

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

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

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

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

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

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

A crossroads for scale up capital

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

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

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

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

The big news: VCT income tax relief reduced

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

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

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

Two things stand out:

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

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

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

Limits lifted across the board

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

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

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

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

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

Industry reaction: a mix of optimism and unease

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

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

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

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

So, what does this mean for advisers today?

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

1. Revisit suitability tests for VCT and EIS

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

Consider revisiting:

• client risk appetite versus early-stage exposure

• diversification across managers and sectors

• liquidity expectations for clients nearing retirement

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

2. Adjust client conversations around relief

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

Client conversations may benefit from focusing on:

• the investment case rather than the relief

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

• time horizons and exit expectations

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

3. Expect product design changes from providers

Managers will respond. We may see:

• more follow-on rounds

• more B2B and scale up focused portfolios

• new liquidity mechanisms

• additional investor education

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

A wider trend toward “structured incentives”

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

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

Final thoughts

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

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

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

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

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

A Budget shaped by speculation, but still containing important changes

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

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

The changes that matter and how they affect advice processes

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

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

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

Actions:

⭐Update factfind templates

⭐Add a short line in suitability reports where relevant

⭐Consider consolidation of cash savings into wrappers

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

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

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

Actions:

• Identify clients currently above the limit

• Reassess pension funding strategies

• Update suitability wording

• Confirm whether employers intend to change scheme rules

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

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

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

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

Actions:

• Revisit existing VCT recommendations

• Adjust future recommendations and suitability rationale

• Update template wording around risk reward and tax efficiency

• Check capacity for loss discussions for clients near suitability boundaries

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

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

Actions:

• Update inheritance tax planning assumptions

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

• Review joint planning cases involving BR qualifying assets

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

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

Actions:

• Update cashflow models

• Review tax efficiency of dividend and rental income

• Consider repositioning assets into wrappers where appropriate

• Reflect the change in updated suitability wording

6. Routine annual adjustments

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

Actions:

• Refresh planning assumptions

• Recheck clients near tax boundaries

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

What was expected but did not appear

Several widely predicted measures were absent, including:

• ISA system restructure

• Pension tax overhaul

• Inheritance tax reform

• Capital gains tax changes

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

Supporting clear client conversations after Wednesday’s Budget

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

Helpful approaches:

• Provide a clear summary of confirmed changes only

• Explain that several predicted reforms did not happen

• Keep explanations straightforward and practical

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

• Correct misinformation early to build trust

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

What suitability consultants should prioritise

A concise checklist for suitability consultants and advice support teams:

Suitability wording:

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

• Remove any pre Budget speculative assumptions

Templates and processes:

• Adjust ISA age banding

• Refresh VCT and BR language

• Update pension contribution and sacrifice logic

• Monitor provider commentary

Governance:

• Note all changes and rationale for audit clarity

Final reflections

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

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

Useful sources referenced:

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

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

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

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

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