TL;DR: FCA targeted support lets firms make recommendations to groups of consumers with common characteristics, sitting between generic guidance and regulated advice. It requires a dedicated FCA permission with a £500,000 minimum capital requirement. Your advice files must evidence products and services, price and value, consumer understanding, and consumer support before the FCA asks. Manual spot-checks typically cover around 15% of cases, so the practical shift is to check 100% of files. Colin runs 42 automated checks on suitability reports against Consumer Duty and COBS standards, giving you a pass/fail view of file readiness without adding headcount. Request a demo or start a 14-day free trial with no credit card required, and contact AdvisoryAI directly for current pricing.

FCA targeted support is designed to allow firms to make recommendations to groups of consumers with common characteristics, directing people to products or actions that could put them in a better financial position, without the individualised personal assessment that regulated advice requires.

The FCA introduced this framework to address a stark problem: 8.6% of UK adults (4.6m) received regulated financial advice about investments, pensions, or retirement planning in the 12 months to May 2024.

The question you face is not whether the advice was sound. It is whether your files prove it. The evidence burden falls on your documentation: suitability reports, meeting notes, fact-finds, and fair value assessments must be complete, consistent, and auditable before the FCA requests them.

Core Requirements of FCA Targeted Support

Targeted support sits between generic guidance and regulated advice. Under the framework, firms can suggest actions to consumer groups with shared characteristics, such as directing pension savers toward appropriate drawdown strategies or prompting cash savers toward investment products. A key intended difference from regulated advice is that no individualised assessment of each consumer's personal circumstances is required.

The framework operates under specific conditions:

• Group-level design: Recommendations target consumer segments, not individuals.

• Defined product scope: Expected to cover pensions and retail investments.

• FCA permission required: You must apply for and be granted a new targeted support permission.

• Minimum capital requirement: A permanent £500,000 capital requirement applies.

Firms are expected to update their systems, create new policies and procedures, train staff on the new requirements, and create appropriate consumer-facing materials before offering targeted support. You must be able to demonstrate that your operational infrastructure supports the evidence requirements from day one.

Evidence Required for FCA Targeted Support

Under Consumer Duty, firms are expected to evidence compliance across four outcome categories: products and services, price and value, consumer understanding, and consumer support. That duty to evidence applies to every service type, but what the file must contain differs: regulated advice requires a full individual suitability assessment, while targeted support does not require an individualised assessment of each consumer's personal circumstances. A recommendation to consolidate pension arrangements, for example, would require a more individualised assessment than firms are permitted to provide through targeted support. The FCA's guidance on designing consumer segments sets out the evidence firms need to justify a group-level recommendation. The categories below show common evidence areas and how Colin checks each one:

FG22/5 requires firms to maintain records that evidence their outcomes monitoring. There's no prescribed format, but the FCA expects those records to support a clear view of whether customers are receiving good outcomes. Firms whose adviser documentation captures recommendation rationale, client circumstances, and action items consistently are best placed to evidence all four outcomes.

Who Must Comply with FCA Targeted Support?

Assessing Your Firm for FCA Intervention

Any firm offering pensions or retail investments falls within scope, including financial advisers, investment platforms, fund managers, retail banks, life insurers, and pension providers. If you intend to deliver targeted support, apply for the relevant regulatory permission. The FCA expects the application process to test whether you have the systems, controls, and record-keeping infrastructure to deliver targeted support compliantly from launch.

That expectation lands hardest on large advice networks, consolidators, and investment management firms, where targeted support evidence must hold up across hundreds of advisers and thousands of consumer interactions. AdvisoryAI is designed for that institutional scale, giving compliance leads consistent, auditable file checking across every adviser in the firm.

Meeting Consumer Duty Requirements

Consumer Duty does not distinguish between service types when it comes to the outcomes you must evidence. What differs is the content of the file, not the obligation to evidence it. The FCA's PS22/9 established that firms must understand and evidence whether client outcomes are being met. The documentation discipline is an extension of what Consumer Duty already demands: structured, auditable files that demonstrate how you assessed client needs, what you recommended, and why. Targeted support reaches consumer groups, meaning your evidence processes must work consistently across hundreds or thousands of client interactions.

Key FCA Red Flags to Monitor

The FCA's supervisory toolkit includes routine supervisory dialogue, thematic reviews, firm-specific reviews, section 166 skilled person reviews, and information requests, with firms identified for inclusion typically receiving substantial information requests on tight deadlines.

Three signals should trigger internal review:

1. Inconsistent documentation across advisers. If file quality varies between advisers, the weakest file defines your firm's regulatory exposure.

2. Gaps in ongoing advice records. The FCA expects robust processes for analysing the ongoing advice back-book, identifying gaps, and managing client redress where service delivery has fallen short.

3. Missing fair value assessments. The FCA's Enforcement Watch newsletter disclosed 11 open investigations into potential Consumer Duty breaches by its second edition on 7 July 2026, up from 6 in its first edition on 28 January 2026, with fair value among the areas under scrutiny.

Steps to Meet FCA Targeted Support Requirements

1. Review the FCA's Specific Requirements

Start with the primary source. PS25/22 sets out the targeted support framework, the permission requirements, and the conduct rules that apply. The FCA will assess your application against those conditions directly.

Alongside PS25/22, review the Consumer Duty final guidance (FG22/5) for the evidence standards that apply across all four outcomes. The FCA has made clear that consumer understanding requirements sit in PRIN 2A.5 and Chapter 8 of the finalised guidance, and these apply to targeted support communications as much as they apply to regulated advice documents.

2. Collate Mandatory FCA Evidence

Build your evidence base around the four Consumer Duty outcomes:

• Products and services: Target market definitions, product design rationale, distribution records.

• Price and value: Fair value assessments, fee transparency documentation, value monitoring data.

• Consumer understanding: Communication testing results, comprehension evidence, support channel records.

• Consumer support: Response time data, vulnerability identification records, complaints handling evidence.

The FCA expects you to demonstrate good outcomes across all four Consumer Duty outcomes with evidence that is data-backed, outcome-specific, and supported by a clear audit trail. If your current documentation workflow does not produce this evidence as a natural byproduct of the advice process, you have a structural gap that manual effort alone will not close.

3. Validate Your Firm's FCA Records

In practical terms, validation involves checking client files against the evidence standard before the FCA asks to see them. The traditional approach of periodic manual file review has two structural weaknesses: sampling means most files are never checked, and manual review is slow and expensive, creating pressure to reduce coverage.

A more defensible approach is continuous automated checking. Every file gets checked, not a sample. Every gap gets flagged with specific remediation guidance. Colin reads fact finds, risk assessments, and the report itself, mapping statements against COBS standards and Consumer Duty outcomes while maintaining an audit trail. Every generated document carries version history, so firms can see who changed what and when. Firms can enforce compliance approval as a gate before a document is finalised, and centrally lock templates and standard wording so advisers cannot drift from the firm's approved format. The result is a firm-wide view of file readiness, not a spot-check of whichever files the compliance team reached this quarter.

4. Meet Critical FCA Submission Deadlines

When the FCA issues an information request, the response deadline is non-negotiable. Under the Financial Services and Markets Act 2000, the FCA operates within statutory timeframes, and firms receiving information requests must respond within the specified period.

If your advice files are incomplete when the request arrives, you will not have time to reconstruct them. The firms that respond well to FCA requests are the ones whose files are already complete, consistent, and auditable.

Manual compliance checking is time a paraplanner could otherwise spend on client work. Colin replaces that manual checking with automated pass/fail verdicts and specific remediation guidance, covering every file, not a sample. Plans run on a monthly rolling agreement with a 30-day money-back guarantee and a 10% discount on annual plans. Contact AdvisoryAI directly for current pricing.

Key Evidence to Satisfy FCA Audit Demands

Evidence Requirements for Client Files

A defensible client file under targeted support is not the same as a file prepared for regulated advice. The FCA treats these as distinct regimes with different requirements: targeted support aligns individuals with consumer segments and provides ready-made suggestions, while regulated advice rests on a comprehensive assessment of the individual's full circumstances. FCA Handbook COBS 9B.3 confirms that targeted support is not subject to the suitability standards in COBS, whereas regulated advice must meet full suitability requirements under COBS 9. The documentation disciplines still overlap. The file must show how the consumer was matched to a segment, why the suggested action fits that segment's common characteristics, and the rationale behind the recommendation.

The specific documents vary by firm, but the categories are consistent:

• Fact-find: Complete client profile covering identity, financial position, objectives, and risk tolerance.

• Meeting notes: Structured record of what was discussed, agreed, and actioned.

• Suitability report: Clear recommendation with documented rationale tied to the client's circumstances.

• Fair value assessment: Evidence that the recommended product or service delivers fair value for the client segment.

• AML documentation: Identity verification and anti-money laundering checks.

The FCA's consumer understanding guidance adds a further layer: firms are expected to test and evidence that consumers understand the communications they receive, using methods such as comprehension checks, surveys, and callbacks. For your files, that means showing not just what the adviser concluded, but how the conclusion was communicated and what evidence exists that the client understood it.

Meeting FCA Suitability Standards

Suitability under targeted support differs from regulated advice in one critical respect: the recommendation is designed for a consumer group, not an individual. But the duty to document remains the same, and the file must still be complete, consistent, and auditable. Your file must show that the recommendation was appropriate for the target group, that you assessed the group's common characteristics, and that the suggested action would put those consumers in a better financial position.

Colin's 42 automated checks on suitability reports cover the core categories the FCA examines: AML documentation, client profiling completeness, risk assessment adequacy, recommendation suitability, and report quality. Each check produces a pass/fail verdict with specific remediation guidance, so a file that scores 95.24% (40 of 42 checks passed) tells the compliance team exactly which two checks failed and what to fix. The 42-check framework also covers multi-category checks on fact-finds, ensuring the underlying client data meets the same standard as the report built on top of it.

How to Audit Your Advice File Evidence

Audit your advice file evidence by testing whether a third party could reconstruct your reasoning from the file alone. Cover three dimensions:

1. Completeness: Does the file contain all required documents (fact-find, meeting notes, suitability report, fair value assessment, AML records)?

2. Consistency: Do the documents tell the same story, or do the meeting notes contradict the suitability report?

3. Traceability: Can every statement in the report be traced back to a source document or meeting record?

Traceability is where most firms struggle. A suitability report that says "the client has moderate risk tolerance" must link to the risk assessment that produced that conclusion. Without this, the file is a collection of assertions, not evidence.

Emma cites every statement in a report back to its source document, so a reviewer can trace each conclusion to its evidence. Colin's compliance file-check step then reviews the report before sign-off. The compliance reports show pass/fail status per category with a percentage score, giving you a firm-wide view of file quality at a glance.

Fair Value Evidence Requirements

Your fair value assessment under targeted support must demonstrate that the products and services you recommend deliver fair value to the target consumer group. This goes beyond fee transparency. The FCA expects evidence that you assessed whether the total cost of the product or service is proportionate to the benefit the consumer group receives.

The FCA's ongoing advice review findings confirm that ongoing advice records form a critical part of the management information needed to prove clients receive fair value and that services paid for are actually delivered.

The enforcement risk is material. The FCA has opened investigations into potential fair value breaches and is using voluntary requirements and own-initiative requirements to restrict firms while investigations run.

Self-Assess Your Documentation Against FCA Standards

Automating FCA Compliance File Reviews

Manual file review creates a structural conflict: the more thoroughly you check, the more time it takes, and the fewer files you can cover. Colin's compliance file-check step lets firms move from spot-checking a sample of cases (commonly around 15%) to reviewing 100% of cases, surfacing higher-risk cases as flagged alerts so compliance leads review by exception rather than at random. Colin is system-agnostic, meaning it checks any suitability report, meeting note, fact-find, or client file against FCA Consumer Duty requirements and COBS standards, regardless of which platform produced the document.

The practical workflow:

1. Upload the document (suitability report, fact-find, meeting note, or file).

2. Colin runs the checks against Consumer Duty and COBS requirements.

3. Review the compliance report showing pass/fail per category with a percentage score.

4. Apply the remediation guidance for any failed checks before the file goes to the client or into the archive.

The AdvisoryAI platform walkthrough shows how compliance reports appear within the platform, and the Colin product overview demonstrates the checking process on a sample suitability report. Every check produces an auditable record, so you can demonstrate to the FCA not just that files were reviewed, but that they were reviewed against specific regulatory requirements with documented outcomes.

How to Meet FCA Evidence Requirements

Meeting FCA evidence requirements is an operational design problem, not a compliance knowledge problem. Most firms know what the FCA expects. The gap is between knowing and doing consistently across every adviser, every file, every day.

The AI Framework for Advice Firms sets out how AdvisoryAI approaches this: all outputs are grounded in the firm's own data with source citations, gated by mandatory human review before any client use. The automation flags gaps and suggests fixes. You or your compliance lead makes the final judgment.

How to Rectify Missing Advice File Data

FCA Consequences for Evidence Gaps

When the FCA identifies evidence gaps, the consequences escalate quickly. The FCA's supervisory approach centres on supervision as the primary mechanism for securing outcomes, with enforcement operating in the background. Where concerns arise, it favours pre-emptive remediation by firms and imposes requirements or variations of permission to restrict firms and compel remediation.

The FCA's own guidance acknowledges that firms with gaps in their records should take additional steps to mitigate the risk of harm to consumers, such as through enhanced outcomes testing for affected customers.

The practical consequences of unremediated gaps include supervisory escalation, business restrictions, and redress obligations. The FCA's own multi-firm review of ongoing advice is direct: if the FCA reviews your firm, you must show robust processes for analysing your ongoing advice back-book, identifying gaps, and managing client redress fairly where service delivery has fallen short.

Steps to Rectify Compliance Gaps

Rectification follows a structured sequence:

1. Audit the back-book: Review ongoing service delivery records to establish a baseline. The FCA's own multi-firm review recommends going back to 2018 for ongoing service records.

2. Identify and categorise gaps: Which files are missing which documents? Which checks fail most frequently across the firm?

3. Prioritise by risk: Files with the largest gaps and the highest consumer impact come first.

4. Remediate systematically: Fill the gaps using specific remediation guidance from your compliance checking process.

5. Document the remediation: The FCA expects evidence that you identified the gap, assessed its impact, and took corrective action.

For firms processing this manually, step 1 alone can consume weeks of paraplanner and compliance officer time. Automated checking compresses this by running every file through the same checks simultaneously, producing a firm-wide gap analysis in hours rather than weeks.

Request a demo to see how Colin checks your advice files against FCA targeted support and Consumer Duty requirements, or start a 14-day free trial with no credit card required. Every plan runs on a monthly rolling agreement with no lock-in, includes a 30-day money-back guarantee, and offers a 10% discount on annual plans.

FAQs

How Long Do I Have to Respond to FCA Targeted Support?

Response deadlines vary depending on the type of FCA request. Information requests typically carry tight deadlines specified in the request itself, and the FCA operates under statutory timeframes for its own processes. You should treat every FCA information request as urgent and respond within the stated period.

Can I Request an Extension on the Deadline?

Extensions are possible but not guaranteed. The FCA considers extension requests on a case-by-case basis, and you should submit any request before the original deadline expires with a clear explanation of why additional time is needed. Relying on an extension as a default strategy signals weak operational readiness.

What If I Don't Have All the Evidence Requested?

The FCA expects firms with record gaps to take additional steps to mitigate the risk of harm to consumers, such as enhanced outcomes testing for affected customers. Proactively acknowledging gaps and presenting a remediation plan produces materially better outcomes than the FCA discovering the gaps independently.

Does Targeted Support Mean My Firm Is Under Investigation?

Receiving a targeted support request or applying for targeted support permission does not automatically mean you are under investigation. However, the FCA favours supervision as its primary mechanism for securing outcomes, with enforcement operating in the background and requirements or variations of permission imposed where concerns arise, so supervisory attention can still escalate quickly if evidence gaps emerge during the review.

How Can I Prevent Receiving Targeted Support in Future?

Prevention centres on documentation quality: firms whose advice files are complete, consistent, and auditable across every adviser are less likely to attract supervisory attention. Running automated compliance checks on every file before documents leave the adviser's desk catches gaps at the point of creation rather than at the point of FCA review.

Key Terms Glossary

Targeted support: An FCA framework allowing firms to make recommendations to groups of consumers with common characteristics, sitting between generic guidance and regulated advice, as defined in PS25/22.

Consumer Duty: The FCA's regulatory framework (PS22/9, FG22/5) requiring firms to deliver good outcomes for retail customers across four categories: products and services, price and value, consumer understanding, and consumer support.

Suitability report: The document that records the adviser's recommendation, the client's circumstances, and the rationale connecting the two. Under Consumer Duty, this must demonstrate traceability from conclusion back to source evidence.

Fair value assessment: The documented evaluation of whether a product or service delivers value proportionate to its total cost for the target consumer group, as required under the Consumer Duty's price and value outcome.