TL;DR: Platform selection demands segmentation by client mandate, full documentation, and a documented review cycle you can justify per client segment, which matters more now the FCA has consulted on replacing the fixed annual review (CP26/10, closed May 2026) and a policy statement is pending. The FCA expects a CIP to be suitable for the individual client rather than applied wholesale, with a clear audit trail behind the decision. Every platform assessed requires a documented outcome, including a clear rationale for those not selected, and the file must show a compliance supervisor why each decision was made, not just what the decision was. Ongoing monitoring keeps platform selection defensible, not a one-off procurement exercise.

In its thematic review of research and due diligence, the FCA found that many firms demonstrated inconsistent and insufficient research and due diligence in the selection of platforms, driven in some cases by status quo bias and by retro-fitting due diligence to justify a decision already made. The FCA's review of fair value frameworks found firms planning to rely on high-level or unevidenced arguments that their business model is inherently fair value, and said firms need to consider how they can evidence that view. Periodic market review is one practical way to build that evidence. Platform selection is a direct input to that evidence. This playbook sets out a structured, repeatable framework for building a platform due diligence process that survives regulatory scrutiny, from requirements definition through to the annual review cycle and, where necessary, a defensible platform exit.

Why Platform Due Diligence Reduces Regulatory Risk

Platform due diligence is a continuing obligation, not a decision made at firm formation and revisited only when something goes wrong. The platform extends your firm's service delivery, which means you retain ultimate regulatory responsibility for the outcomes it enables or prevents.

The FCA's thematic review describes good practice as making research and due diligence a central function of the advice process, demonstrating that the client's best interests are driving it, and embedding a culture of challenge within the firm. Comprehensive documentation strengthens your audit trail. Every selection decision, and every rejection, requires a documented rationale that a compliance supervisor can follow.

Meeting Consumer Duty and COBS Requirements

Under the price and value outcome in FG22/5, Consumer Duty requires firms to consider whether the total cost of advice to the client, including all platform and product fees, represents fair value. A comprehensive assessment should account for platform charging structures, wrapper fees, trading costs, and the service quality delivered in return. A defensible assessment considers multiple dimensions of value, not just annual fee comparisons. Platform selection is an important component of demonstrating value to clients.

The FCA's consultation on replacing the fixed annual review with periodic reviews based on client needs increases firms' responsibility to justify their chosen review cycle, which requires rigorous underlying documentation.

Avoiding File Note Inconsistencies

Inconsistent file notes across advisers in the same firm are a significant source of regulatory exposure, and with 43.3% of advisers reporting in AdvisoryAI's own research that paperwork reduces the time they can devote to advice, the documentation shortcuts that create inconsistency are predictable under pressure. When one adviser documents a thorough platform rationale and another records only a brief summary, weak files can materially impact your firm's compliance profile during a supervisory review.

Available within the AdvisoryAI platform, Colin runs automated checks on suitability reports and file notes against FCA Consumer Duty requirements and COBS standards, generating pass/fail verdicts and guidance before any document leaves your desk. Colin is system-agnostic, so it checks any suitability report or file note regardless of which tool produced it. Firms do not need to migrate their existing documentation workflow to benefit.

Structuring Your Platform Selection Process

Defensible selection processes follow a four-phase structure: requirements definition, market filtering, provider assessment, and documentation. Each phase produces specific outputs that feed directly into your audit trail.

Table 1: A four-phase platform due diligence framework

Evidence Required for Platform Selection

Gather documentary evidence for each platform assessed, not assertions. Hold the following for each provider:

• Fee schedules at relevant CIP investment tiers

• Written responses to RFP questions covering SLA commitments, data residency, and security standards

• Notes from meetings or calls with platform business development managers, including action points

• Evidence of how the platform handles scenarios relevant to your client base

• The completed scorecard with individual criteria scores and total weighted result

Demonstrating Ongoing Oversight to the FCA

Demonstrate ongoing oversight with more than an annual score update. Maintain a log of service incidents, platform communications on fee changes or corporate activity, and any consumer complaints related to platform issues. This log can sit alongside the annual scorecard review and demonstrates active oversight as a continuous process, not a single annual event.

Designing Your Platform Due Diligence Scorecard

A quantitative scorecard removes subjective bias and produces a defensible, repeatable comparison that feeds directly into the audit trail. The process has four steps.

Step 1: Identify Key Platform Metrics

For each of the four scoring categories, define the specific sub-metrics you will assess. Cost considerations include total platform charges at relevant investment tiers, not just the headline custody rate. Technology considerations cover API capabilities and whether the platform supports synchronisation with the back-office systems your firm uses. Financial strength considerations include AUA trajectory, credit ratings, and ownership structure. Client experience considerations cover portal usability, reporting clarity, and administration response times.

Step 2: Weight Metrics by Client Mandate

Change your weights based on the client segment in question. For retirement income clients, drawdown capability, Bed and ISA functionality, and the quality of death claim administration carry more weight than accumulation tools. For accumulation clients, trading costs and digital client experience may rank higher. Minimum fee structures can create a disproportionate cost burden for clients at different investment levels.

Client needs also change over time. A platform that suited your client base three years ago may no longer represent fair value for clients whose investment circumstances have shifted, which is why weighting reviews should accompany platform reviews.

Step 3: Define Your Scoring Methodology

A simple 1-to-5 scale works well in practice. Score 5 where the platform fully meets the criterion with documented evidence, 3 where it partially meets it with known limitations, and 1 where the criterion is not met. The weighted total then produces a numeric result comparable across providers, which you reference in the audit trail.

Step 4: Record the Result in the Audit Trail

Before finalising the scorecard, test your own documentation. Ask whether a compliance supervisor reviewing your file could identify, from the documentation alone, why Platform A scored above Platform B on client experience and why Platform C was removed from the shortlist at the filtering stage. If you cannot answer clearly from the file alone, the documentation is incomplete. Once the test passes, record the weighted totals, the narrative rationale for the selected platform, and the rationale for each rejected platform in the due diligence report. This output feeds directly into the sign-off pack reviewed by the Investment Committee or Board.

Essential Pre-Assessment Filters

Not every platform that clears initial shortlisting merits a full scorecard assessment. Apply non-negotiable filters at the outset to focus the detailed work on genuinely viable providers.

Platform Costs and Charging Structure

Assess both explicit and implicit costs. Explicit costs include custody fees, trading charges, and wrapper fees. Implicit costs may include revenue-sharing arrangements with fund managers, platform-directed rebates, or service charges embedded in DFM model portfolio costs.

The Value for Money assessment under Consumer Duty benefits from documentation at the level of the individual client segment, providing clearer evidence of fair value for each group served.

Aligning CIP with Investment Tiers

The FCA's thematic review is explicit that a firm operating a CIP must still ensure the advice is suitable for the individual client, and that advisers must understand the benefits and risks of the CIP well enough to identify clients for whom it is not suitable. The rationale for using one platform across multiple CIP tiers must therefore be explicitly argued, not assumed. If your firm serves both accumulation and decumulation clients from one platform, your due diligence file must address both segments directly.

Conducting a Robust Platform Assessment

Gathering Reliable Platform Data

Avoid relying on marketing materials or product summaries. Request written responses to structured RFP questions, and treat verbal BDM commitments as discussion points rather than evidence unless confirmed in writing.

Evie records meetings held via Microsoft Teams, Zoom, or Google Meet and produces structured notes with action items broken out and a searchable record created after the meeting. Watch how AdvisoryAI's platform works to see how meeting notes and document generation fit together in a single workflow.

Structuring Platform RFP Questions

Structure RFP questions to generate specific, verifiable answers rather than broad assurances. Draft questions across these key categories:

1. Security and data residency: Where is client data held? What certifications does the platform hold (ISO 27001, Cyber Essentials)? What is the incident response protocol?

2. SLA commitments: What are the guaranteed transfer turnaround times for full and partial encashments? What remediation applies if SLAs are breached?

3. API and integration scope: How many client data fields does the API expose? Which back-office systems are confirmed integrations? What is the version control process for API updates?

4. Consumer Duty alignment: How does the platform support the Consumer Support outcome? What client-facing reporting does it provide?

5. Business continuity: What is the platform's recovery time objective in the event of a major service outage?

6. Pricing stability: How much notice does the platform give before fee changes? What is the contractual lock-in period?

Table 2: Technical integration considerations for back-office compatibility

AdvisoryAI's Intelliflo integration shows what two-way integration looks like in practice: fact-find data captured in a client meeting populates specific fields in Intelliflo's fact-find section (personal information, investment details, employment details), removing the manual re-entry step that advisers routinely cite as a source of friction.

Testing Platforms with Real Scenarios

Before finalising the scorecard, run scenario tests relevant to your client base. For retirement-focused firms, a complex death claim and a large partial withdrawal provide valuable evidence. For accumulation-focused firms, an ISA transfer and a model portfolio rebalance offer comparable insight. Document the outcome of each test, including any steps that required manual intervention or produced errors, and factor the results directly into the client experience score.

Documenting the Rationale for Your Chosen Platform

The final due diligence report should do more than confirm which platform was chosen. It should explain why, with reference to the specific client segments it serves and the evidence gathered during the assessment.

A robust due diligence report contains these sections as a minimum:

• Executive summary: Platform selected, client segments served, and headline rationale

• Scope of review: Platforms assessed, review timeframe, and team members involved

• Scoring methodology: Criteria used, weighting per client segment, and scoring definitions

• Results summary: Weighted scores for each platform in a comparison table

• Narrative rationale: Written explanation of why the selected platform scored highest, referencing specific evidence gathered during the assessment (for each rejected platform, document the primary disqualifying factor or score shortfall and the decision date)

• Sign-off record: Confirmation that the Investment Committee or Board reviewed and approved the selection, with the board minutes recording the decision and the date it was made. Documenting why certain platforms were not chosen strengthens the defensibility of your selection, demonstrating that a genuine selection process took place rather than a retrospective justification for a platform already in use.

Monitoring Platform Performance and Compliance

Evidence Requirements for Annual Reviews

The FCA has consulted on replacing the fixed annual suitability review requirement with a flexible periodic obligation, requiring firms to determine review frequency based on client needs, risk characteristics, and investment complexity. For platform due diligence, many firms continue with annual full reviews alongside ad-hoc reviews triggered by specific events. Each annual review should produce a refreshed scorecard, a narrative comparison to the previous year's findings, and a written conclusion on whether the platform continues to represent fair value for each client segment. If the conclusion is that it does, you must evidence it, not assume it.

KPIs for Ongoing Platform Performance

Track these KPIs between full annual reviews:

• Transfer turnaround times (full and partial encashments) versus SLA

• Administration error rate and remediation turnaround

• Client portal uptime and reported access issues

• Platform fee changes and effective date of notification

• Any service incidents, their root cause, and the platform's remediation response

This data feeds directly into the annual review and provides early warning of performance deterioration that may require an unscheduled assessment.

When to Initiate a Platform Switch

Platform exit decisions are among the most consequential a firm can make, and Consumer Duty requires careful documentation of the rationale. Common triggers that may justify initiating a review outside the annual cycle include a significant and sustained SLA breach affecting client outcomes, a fee increase that materially alters the Value for Money conclusion, a platform ownership change raising counterparty risk, the introduction of a new CIP tier the existing platform cannot adequately support, or evidence from client experience data that outcomes are deteriorating.

When you consider a switch, the decision file should contain the original selection rationale, the performance data that identified the shortfall, the evidence that you weighed switching costs against long-term client benefit, and the board sign-off on the decision to proceed.

How AdvisoryAI Supports Platform Due Diligence

Atlas is the AI chat and intelligence layer within the AdvisoryAI platform that lets you query the client data, meetings, documents, and back office you have synced, across Intelliflo, Plannr, and Curo, in plain English. Its Adaptive Thinking capability makes its reasoning fully visible as it works: live status updates display each step as it processes, a collapsible thinking block reveals the step-by-step reasoning behind every response, the input locks during processing to prevent duplicate sends, and reasoning persists across sessions, so older queries remain auditable when files are reviewed for compliance defensibility.

Atlas remembers context across sessions, the headline live capability that changes how firms interact with their data. Fund and product research capability is also on the Atlas roadmap, alongside DFM and model-portfolio comparison and plain-English workflow automations. Firms should confirm current availability directly with AdvisoryAI. Evie, Emma, and Colin are capabilities within Atlas rather than separate tools.

Why Firms Choose AdvisoryAI

AdvisoryAI was ranked the number one AI system among UK advisers in the AI-only category for H1 2025 by AdviserSoftware, as featured in FT Adviser, and is the number one most-viewed tech tool on AdviserSoftware.com, reflecting adoption by practitioners who tested the products against real workflows. The platform was built by a team including CTO Roshan Tamil Selvan (MIT Masters in AI/ML), with models trained on thousands of sample reports by ex-advisers and paraplanners. All plans operate on monthly rolling agreements with a 30-day money-back guarantee, and annual plans include a 10% discount.

For Operations Directors and compliance leads at multi-adviser firms, request a demo to see how Atlas and Colin integrate with your back office to build a defensible audit trail. For advisers and paraplanners who want to test the products directly, start a 14-day free trial with no credit card required, on a monthly rolling agreement with a 30-day money-back guarantee.

FAQs

How Often Should Platform Due Diligence Be Conducted?

Most firms conduct a full review every 12 months as a baseline, with ad-hoc reviews triggered by specific events: a significant SLA breach affecting client outcomes, a fee change that alters the Value for Money conclusion, or a platform ownership change raising counterparty risk. The FCA has proposed replacing the fixed annual review with periodic reviews based on client needs, so firms should be ready to document why their chosen cycle is appropriate for each client segment.

What Does the FCA Expect Firms to Document in a Platform Due Diligence File?

The FCA expects documentary evidence of the market research that produced your shortlist, and detailed due diligence on the providers you shortlisted. In practice that means evidencing cost, technology, financial strength, and client experience for each one. Every platform assessed requires a documented outcome, including a clear rationale for platforms not selected. Assertions are not sufficient. The file must show a compliance supervisor why each decision was made, not just what the decision was.

Do We Need Board Approval to Change Our Approved Platform List?

Most firms require formal sign-off from the Investment Committee or Board before any change to the approved platform list takes effect. The supporting evidence, the decision rationale, and the date of approval should all appear in the board minutes. Without that record, the audit trail for any subsequent FCA review will have a material gap.

How Long Should Platform Due Diligence Files Be Retained?

Retention depends on the record. Under COBS 9.5.2R, suitability records run to three years in the general case, five years for life policies and pension products, and indefinitely for pension transfers, conversions, opt-outs, and FSAVCs. Platform due diligence files, scorecards, and BDM meeting records generally sit outside COBS 9.5 and under your firm's general record-keeping policy, though firms should confirm the classification with their compliance lead. Under Consumer Duty's ongoing value-for-money obligations, retaining them for the duration of the client relationship is the more defensible position, as it allows you to evidence how the platform selection decision was made relative to each client's evolving circumstances.

Can Colin Review Documents Created in Other Systems?

Yes. Colin checks any suitability report, file note, or due diligence document regardless of which system produced it, running automated checks against FCA Consumer Duty requirements and COBS standards and returning pass/fail verdicts and specific guidance before any document leaves the adviser's desk.

What Triggers a Platform Switch Under Consumer Duty?

Consumer Duty does not prescribe a fixed trigger, but it does require firms to act where evidence shows a platform is no longer delivering fair value to a specific client segment. Common triggers include a sustained SLA breach with demonstrable impact on client outcomes, a fee increase that materially alters the Value for Money conclusion, a platform ownership change that raises counterparty risk, or client experience data showing the Consumer Support outcome is deteriorating. Where any of these arise, the decision to review, defer, or switch must be documented alongside the evidence that informed it, including the weighting given to switching costs against long-term client benefit.

Key Terms Glossary

Centralised Investment Proposition (CIP): A firm's defined set of investment strategies and recommended wrappers typically applied consistently across client segments, used to standardise advice quality and simplify compliance oversight, though the advice must still be suitable for each individual client.

Value for Money (VfM) Assessment: An analysis under Consumer Duty demonstrating that the total cost of advice, including platform and product fees, is proportionate to the benefits the client receives.

Investment Book of Record (IBOR): The record of a client's investment holdings maintained by the platform, which must reconcile accurately with back-office systems to prevent data discrepancies in client reporting and advice documentation.

System-agnostic compliance checking: The capability of a compliance tool to review documents produced in any system, allowing firms to check advice files regardless of how or where they were originally drafted.