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Regulation Roundup: Autumn Budget, FCA Simplification, and What Advisers Need to Watch

By
Team We Complement

The Autumn Budget: What Next for Advisers?

The Autumn Budget has been announced for the 26th of November – the first time it has been held at the end of November since the mid-1990s. In the 12 weeks between now and the Budget, there is likely to be a lot of speculation surrounding the changes that might be made.

The Professional Paraplanner summary is a good starting point. Key points to flag:

  • ISAs and pensions remain central –  speculation from AJ Bell that the government could combine Cash ISAs and Stocks and Shares ISAs into a single product. Changes to pension tax relief is an area that has been speculated about for some time, and it looks like this discussion is set to continue in the run up to the Autumn budget.
  • Tax treatment remains in flux – further IHT changes are likely to be unwelcome after the recent changes to IHT. However, the government has backed itself into a corner slightly, having ruled out increasing income tax, NI and VAT. Something has to give. There has been talk of ‘stealth’ IHT tax increases (such as freezing IHT thresholds again), potentially a wealth tax, or changes to council tax.
  • Policy continuity matters – with a budget on the horizon and speculation rife, clients may be more jittery about long-term planning, leading to “knee-jerk reactions based on rumours.”

The practical takeaway? Stay close to policy updates, and frame client conversations around resilience rather than chasing headline tax moves. The rules may shift, but the principles of building buffers, using allowances, and stress-testing plans don’t.

 

The Ongoing Puzzle of Tax-Free Lump Sums

One area where complexity persists is the treatment of tax-free lump sums under primary and enhanced protection. The Professional Paraplanner technical note is worth bookmarking.

Why it matters:

  • The interaction between the lifetime allowance and the new rules can be a little complicated.  This helpful article takes you through the main technical points you need to know, as well as some helpful examples.
  • Many clients assume 25% tax-free cash is always available. In fact, protections layered on pensions since 2006 create scenarios where entitlements vary.
  • Primary and enhanced protection rules can mean higher tax-free entitlements than the standard allowance – but only if records are clear and the rules applied correctly.
  • Advisers need robust evidence. With Consumer Duty now in force, you’ll need to show not just that the advice was technically correct, but that you’ve explained the position clearly to clients.

Our advice? Document assumptions carefully, and don’t rely on memory or firm lore. Each case needs a file note that could withstand FCA scrutiny if challenged later.

 

FCA Pushes for Simpler, Clearer Communication

The FCA is on a mission to make its own materials less of a maze. Two recent updates signal where things are heading:

This isn’t just housekeeping. It sets an expectation. If the regulator is working to simplify how it talks, advisers and firms will be expected to do the same. Long, technical letters that bury the key message won’t cut it.

Practical tip: review your client letters and suitability reports. Could a non-specialist pick out the key points in 60 seconds? If not, it’s worth a rework.

 

Pension Transfer Lessons

The FCA’s multi-firm review of life insurers’ pension transfer processes highlights themes that apply across the industry. The FCA states the following:

  • Ceding schemes made most transfer payments within a suitable time of receiving the request to transfer. More than three-quarters of the firms in their sample completed all transfer requests, on average, within 20 days.
  • Five firms were responsible for over two-thirds of requests.
  • About 87% of these transfers were processed by firms that told the FCA that they complete all transfers within 15 days.
  • Where a transfer required no additional checks, the FCA found that over three-quarters of the firms completed these transfers within 10 days, with the shortest time being 5 day.
  • ‘Amber flags’ indicating that a pension transfer needs extra checks were applied to less than 2% of transfer requests, most often caused by the receiving scheme including high-risk or unregulated investments; the receiving scheme’s charges being unclear or high; or overseas investments being included in the receiving scheme.

Does this align with your experience of dealing with pension switches?

Bringing It Together: What Advisers Can Do

 

If you only take three things from this roundup, make them these:

  • Simplify your communication – assume every client and regulator wants the headline upfront.
  • Evidence every decision – especially why options weren’t chosen. Assumptions without records are weak points.
  • Prepare for real-time scrutiny – Consumer Duty and the FCA’s direction of travel mean advice needs to be audit-ready as it’s written, not weeks later.

The good news? None of this requires crystal ball gazing. It’s about process discipline, structured reasoning, and a culture of clarity. Firms that embed these habits now will not only stay compliant – they’ll stand out as trusted, modern advisers.

 

Final Word

At We Complement, we see the same patterns across firms: the best ones don’t wait for the regulator to nudge them. They tighten up their evidence, simplify their language, and make sure advisers feel supported rather than exposed.

If this resonates with what you’re seeing, we’d love to hear from you. Drop us a note or share how your firm is approaching these shifts – no pitch, just a conversation with people who get financial advice.

 

 

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