TL;DR: FCA CP26/10 does not create a new standalone regime. It consolidates COBS 9 and COBS 9A into a single chapter (COBS 9C) and allows proportionate, focused advice for straightforward client needs, while keeping Consumer Duty and suitability obligations fully in force. The three-layer framework distinguishes targeted support (non-advised), simplified advice (regulated personal recommendation), and full planning (holistic). Firms that attempt to deliver simplified advice using manual documentation processes will find lower fee structures commercially unviable. Firms that automate meeting notes, suitability reports, and compliance checks using their own templates can protect margins while maintaining regulatory defensibility.

Research across UK advice firms shows 71.9% of firms spend between one and seven hours producing a single suitability report. That time investment makes lower-fee simplified advice commercially impossible under manual processes, which is why the FCA's CP26/10 proposals create a real opportunity for firms that resolve the documentation bottleneck before the policy statement lands in Q4 2026. Only 9% of UK adults currently receive regulated financial advice, and the constraint is not demand or expertise. It is the cost of delivering a compliant advice file for clients with straightforward needs.

CP26/10 changes the regulatory architecture, but it does not change the admin reality. Firms that automate using their existing templates can protect margins under lower fee structures. Firms that treat this as a purely regulatory exercise will find the economics do not add up.

Core Requirements for Simplified Advice Files

The first thing to understand about CP26/10 is what it is not. The FCA considered and rejected creating a separate regulatory framework for simplified advice. Instead, the proposal consolidates COBS 9 and COBS 9A into a single new chapter, COBS 9C, and introduces targeted rule tweaks that permit a more proportionate approach for focused advice cases.

Because simplified advice operates within the existing FCA framework, all of the following remain fully in force:

• Consumer Duty obligations: Under the proposed framework, firms are expected to evidence Consumer Duty outcomes (including products and services, price and value, consumer understanding, and consumer support) in simplified advice files, applying proportionality principles to the focused nature of the advice.

• SM&CR accountability: Senior Managers are expected to retain personal regulatory accountability for advice quality across the firm under simplified advice.

• Suitability requirement: Simplified advice is understood to remain a personal recommendation subject to suitability requirements. Proportionate does not mean exempt.

Firms offering simplified advice must hold FCA authorisation for investment advice, as simplified advice remains a personal recommendation subject to full conduct standards. The debate around targeted or modular adviser qualifications remains open.

The consultation is expected to close in mid-2026, with a policy statement anticipated later in the year. Until final rules are published, firms should assume existing qualification requirements apply and begin operational preparation now. Firms operating under existing FCA authorisation for investment advice are expected to be able to offer simplified advice within the new proportionality framework, restricted to clients with a clearly defined, limited need being recommended straightforward retail products. Cases involving complex needs are expected to fall outside scope and must be handled under full planning rules.

Defining the Three-Layer Advice Framework

The CP26/10 consultation defines three distinct layers of consumer-facing support, each with its own regulatory status, scope, and documentation requirements.

Table 1: The Three-Layer Advice Landscape Under FCA CP26/10

Targeted support allows firms, primarily pension schemes, insurers, and investment platforms, to make suggestions to groups of consumers sharing similar characteristics. Under the proposed framework, targeted support is not a personal recommendation and sits below the personal recommendation threshold, which is why it does not trigger individual suitability requirements under COBS 9 or 9A.

While complaints relating to targeted support come within FOS jurisdiction, the FOS would not expect firms operating within the targeted support regime to conduct the same fact-finding or suitability process required for personal recommendations, provided the consumer has not been misled. Simplified advice, by contrast, is a regulated personal recommendation focused on a specific, limited client need, subject to full suitability requirements albeit with proportionate fact-finding. Full planning covers holistic recommendations requiring comprehensive assessment of a client's complete financial picture.

Distinguishing Simplified Advice from Full Planning

The regulatory boundary between simplified and full advice is where firms face the greatest practical risk. Advice creep, where a focused client conversation gradually expands to cover areas requiring holistic assessment, is the most common compliance failure in this space.

Full planning typically covers cashflow modelling, inheritance tax strategy, defined benefit pension transfers, complex trust structures, and multi-generational wealth planning. Simplified advice covers a focused, transactional need. The difference is not just scope. It is the level of professional judgment required, the depth of fact-find, and the documentation standard expected at audit.

Documenting Suitability Under CP26/10

Under the proposed COBS 9C framework, the depth of the suitability assessment can be proportionate to the focused need. The FCA's proportionality guidance is expected to allow firms the legal basis to conduct a narrower fact-find, provided the information gathered genuinely supports the specific recommendation being made.

Firms would be expected to adopt a risk-based approach, exercising greater judgement in determining what information is needed by reference to the nature and scope of the advice, the complexity of the product or service, and the characteristics of the client, including any vulnerability. What does not change is the outcome requirement: a suitable recommendation must still be suitable. Any flexibility must still align with Consumer Duty, with firms expected to demonstrate that services continue to deliver fair value and meet client needs.

Identifying Suitable Simplified Advice Cases

Concrete examples help clarify where the boundary sits:

Cases that fit simplified advice:

1. A client with cash savings wanting to invest for retirement with no ISA allowance used (illustrative example)

2. An employed client wanting to make additional voluntary contributions to a personal pension (illustrative example)

3. A client approaching retirement wanting to consolidate small pension pots into a single simple personal pension with no defined benefit element (illustrative example)

Cases that must be upgraded to full planning:

1. Defined benefit pension transfers or comparisons involving safeguarded benefits, where firms must continue to comply with additional information requirements in COBS 19 and existing FCA guidance (transfers above £30,000 require regulated advice by law)

2. Clients whose circumstances reveal complexity that cannot be addressed within a proportionate fact-find scope, such as those with complex estate planning needs, trust structures, or IHT mitigation requirements

Adapting Fact-Finds Under the New Regime

The proportionate fact-find is the most operationally significant change for paraplanners and compliance officers, and the area where firms face the greatest risk of getting the documentation wrong.

How to Limit Fact-Find Scope Legally

The FCA's CP26/10 guidance allows firms to omit information that is not material to the specific recommendation being made. The regulatory distinction is between omitting irrelevant data, which is permissible under proportionality, and failing to gather material facts, which is a compliance failure under any regime. When a firm omits sections from a simplified advice fact-find, the file should record the specific areas not assessed, the reason each is justified given the client's stated need, and confirmation that the omission does not affect suitability.

For paraplanners designing proportionate fact-find templates, the process works in four steps:

1. Define the focused need: Capture the client's specific instruction in writing at the start of the engagement.

2. Identify required information: Map the fields genuinely necessary to support that specific recommendation.

3. Document exclusions explicitly: Record which standard fact-find sections are not completed and why, referencing the limited scope.

4. Obtain client acknowledgement: Capture the client's agreement to the limited scope as part of the engagement documentation.

This creates a proportionate file that is both defensible at FCA review and aligned with Consumer Duty's consumer understanding outcome.

Aligning Fact-Finds with Consumer Duty

Even within a limited-scope fact-find, Consumer Duty outcomes must be considered. Consumer Duty's price and value outcome requires firms to assess whether the advice fee represents fair value relative to the focused service being delivered. The consumer understanding outcome requires that the suitability letter is written in plain, accessible language that a retail client can genuinely understand.

Where a client discloses vulnerability markers during the engagement, advisers should consider recording and assessing these, even within a proportionate scope, because they may be material to suitability regardless of the advice framework in use. Evie's meeting notes capture vulnerability markers disclosed during the conversation, which should be assessed and recorded even within a proportionate scope.

Updating Firm Templates for CP26/10 Rules

Template updates are the operational task that most directly affects the firm's ability to deliver simplified advice consistently across all advisers and paraplanners, and where Operations Directors need to focus first.

A common concern is that AI-generated documentation forces firms to abandon their established document formats. We built Emma to work from your firm's own existing suitability report templates, not a standardised vendor format. The document structure, compliance-checked formatting, and advice style your firm has developed remain intact while the manual writing time is removed. Watch how Emma automates suitability letters while preserving firm-specific templates, and see the broader suitability report generation workflow in practice.

A compliant simplified advice suitability letter under the proposed CP26/10 framework is expected to include at minimum four structural elements:

• Scope statement: A clear description of what the advice covers and what it explicitly does not cover.

• Proportionate suitability rationale: Evidence that the recommendation is suitable based on the information gathered, with each claim cited to its source document.

• Consumer Duty evidence block: Explicit statements covering price and value, consumer understanding, and any vulnerability considerations.

• Next steps and disclosures: Actions required, ongoing service obligations, and fee transparency in plain language.

Mapping Suitability to New FCA Rules

The narrower fact-find in simplified advice files must be demonstrably sufficient for the specific recommendation being made, which means every claim in your suitability report must trace back to its source document. Emma generates suitability reports from meeting notes, fact-finds, LOA pack summaries, ceding information, cashflow modelling outputs, and risk profile assessments, designed to support the evidential traceability requirement for proportionate suitability files. Read how we simplify suitability letters for FCA-regulated firms.

For firms running Intelliflo, Plannr, Curo, or Xplan, Evie connects directly with these back-office systems, pushing structured meeting outputs and populating specific fields in the fact-find section, including personal information, investment details, and employment details, directly into the client file. This removes the manual re-entry step that creates reconciliation risk between the meeting record and the back office. You can see Evie's full workflow in this AI meeting notes overview and read how the Intelliflo integration works in practice.

Maintaining Compliant Audit Trails

The audit trail requirement does not diminish under simplified advice. Firms must still demonstrate exactly how the adviser arrived at the recommendation, and the file must be legible to an FCA reviewer who was not present in the meeting. Evie, Emma, and Colin are capabilities within Atlas, AdvisoryAI's single conversational platform, and the audit trail functionality described below reflects how Atlas connects that documentation layer into a reviewable, reasoning-transparent record.

Adaptive Thinking, released May 2026, makes Atlas's reasoning visible as it works. When an adviser queries client data, a live status display shows each step as it processes the request, from analysing the query to loading the client profile. A collapsible thinking block then reveals the full reasoning behind the response, and this reasoning persists with the conversation, meaning older queries remain auditable in the same session record. The input field locks during processing to prevent accidental duplicate sends. Watch Atlas in action to see how the reasoning transparency works.

For compliance teams cautious about black-box AI outputs, Atlas does not hide its work. The platform was built by ex-advisers and paraplanners, with a model trained on thousands of sample reports and a CTO holding an MIT Masters in AI and ML.

Managing Regulatory Risks in Client Files

The practical risk most advisers carry into CP26/10 is not about understanding the rules. It is about whether a simplified advice file will survive a compliance review twelve months after it was produced, when the file must defend itself without the adviser present to explain the reasoning.

Our compliance checker, Colin, runs 42 automated checks on suitability files against FCA Consumer Duty requirements and COBS standards before the document leaves the adviser's desk. Colin works on any suitability report, including those produced in other systems, which means firms can use it to check existing file populations, not only documents generated within AdvisoryAI.

Colin's compliance reports provide pass/fail status for each check category, and checks that do not pass include guidance to support remediation. For simplified advice files, this is particularly valuable because the proportionate scope creates a different compliance risk profile than a full planning file: the risk is not that the file is too complex, but that it looks incomplete without documented justification for the limited scope.

Managing Fee Pressure Under CP26/10

Lower fees for simplified advice are commercially viable only when the time cost per file falls proportionately. Under a manual process, where advisers spend between four and six hours on a suitability report according to AdvisoryAI's whitepaper, a simplified advice file priced at a fixed lower fee produces a direct loss. The unit economics only work when report preparation time is measured in review minutes rather than writing hours.

Research commissioned by AdvisoryAI found annual review time fell by 59.8%, from 5 hours 47 minutes to 2 hours 19 minutes, and suitability letter preparation time fell by 65.48%, from 4 hours 45 minutes to 1 hour 38 minutes, when automation was in use. The Flower Group's valuation modelling shows that doubling adviser capacity through operational efficiency can increase a two-adviser firm's valuation from £1.26m to £3.77m on the same headcount.

Protecting High-Touch Client Files

Firms offering both simplified advice and full planning must build operational controls that keep these file populations separate. Workflow routing controls, which direct clients into the correct pathway at intake, combined with dedicated simplified advice document templates distinct from full planning formats, are the two most effective controls for maintaining this separation at scale.

Lowering the Cost of Simplified Advice with AI

Maintaining Margins with Lower Fees

Advisers at Brooks Macdonald freed 6,000 hours annually across 60 advisers using Evie for their annual review workflow, with meeting write-up time reduced from 2.5 hours to a 30-minute review. That change in time cost per meeting is what makes a lower-fee service commercially viable.

Automating FCA-Compliant File Notes

Evie records client meetings via Microsoft Teams, Zoom, or Google Meet, then produces structured meeting notes covering objectives, circumstances, recommendations, and action items, alongside a draft follow-up email. Evie captures not just what clients say but how they respond, including client anxieties, family dynamics, and health concerns mentioned in passing. This soft facts capture is particularly valuable for vulnerability identification and building a complete client picture. The structured output is available to the full team within minutes of the meeting ending, not days later when the adviser has had time to write up. Watch how Evie captures meeting notes and the full documentation workflow in practice.

The sequential bottleneck this removes is one of the most significant operational gains for simplified advice delivery. When paraplanners and administrators can access the meeting record immediately, cases can be processed in parallel. Timothy James and Partners reported a 50% reduction in post-meeting documentation time, with support teams able to access notes significantly faster.

For LOA-heavy workflows that arise in simplified advice cases involving pension consolidations, Finsource Partners reported an 80% reduction in time spent reviewing LOA packs using Emma's LOA pack summary capability.

Freeing Up Adviser Hours for CP26/10 Delivery

The advice gap is an operational problem, not a marketing one. Millions of UK households with significant investable assets are not being served because advisers run out of hours, not because they lack the expertise. CP26/10 creates the regulatory space to reach more of these clients, and automation creates the operational headroom to do so profitably.

Meeting New Suitability Requirements Under CP26/10

Transitioning the firm's advice proposition to include a simplified advice pathway requires three parallel workstreams: disclosure and commercial documentation, adviser training, and workflow routing.

Adapting Your Offer to CP26/10 Rules

Operations Directors should work through the following before the policy statement is published:

• Update the firm's initial disclosure document to describe the simplified advice service clearly and separately from full planning.

• Revise fee schedules to reflect the separate pricing structure for simplified advice.

• Update service agreements to include the scope limitation disclosure required at the outset of simplified advice engagements.

• Review the firm's target market definition to confirm which client segments are appropriate for simplified advice versus full planning.

• Consider configuring your back-office system to tag simplified advice files separately from full planning files to support internal compliance monitoring.

Updating Firm Processes for CP26/10

Routing clients into the correct pathway before the meeting begins is where Atlas adds direct operational value. Before a client meeting, you can query the client's history across meeting transcripts, prior suitability reports, and uploaded documents through Atlas's conversational interface, identifying whether the client's profile fits the simplified advice criteria or requires a full planning approach. Atlas can support more effective pre-meeting preparation by surfacing relevant client context from historical records.

Fund and product research is on the Atlas roadmap as a near-term development item, which would allow advisers to surface investment research directly alongside client data within the same conversational interface. Firms should confirm current availability directly with AdvisoryAI before factoring this into their CP26/10 implementation planning.

Adviser Training for Suitability Rules

The training priority for simplified advice delivery is maintaining scope discipline throughout the client conversation. Advisers accustomed to holistic reviews will naturally cover areas outside the simplified advice scope, particularly when clients raise adjacent topics. Training should cover how to acknowledge client questions outside scope without inadvertently delivering full planning advice, how to document scope boundaries at the start of the meeting, and how to confirm at the close that the documented scope matches what was actually discussed.

Colin's 42 automated checks provide immediate feedback on draft files with specific remediation guidance, so advisers receive structured compliance coaching on every file they produce. Watch AI's role for paraplanners and the broader impact on advice workflows to understand how compliance feedback loops are changing in UK advice firms.

How to Manage Simplified Advice Compliance

Can Firms Mix Simplified and Full Advice?

Yes. The proposed framework is expected to allow firms to offer both services. A client who receives simplified advice for an ISA investment can subsequently receive full planning for a pension transfer or estate planning review. The requirement is that each engagement is clearly scoped, documented separately, and that any transition from simplified to full planning is recorded in the client file when it occurs.

Updating PI Cover for Simplified Advice

Simplified advice represents a different risk profile from full planning. The limited scope, documented proportionality, and automated compliance checking all reduce exposure from a poorly evidenced advice file. Firms using Colin to check files before they leave the desk can present this process to their PI insurer as a systematic pre-advice quality control, which may be relevant to how the insurer assesses file quality risk. Firms should discuss the CP26/10 implementation with their PI broker directly, covering the new service scope, documentation controls in place, and whether policy wording needs updating.

Scope of Targeted Support Defined

Targeted support is distinct from both simplified advice and guidance. It allows firms, primarily pension schemes, insurers, and investment platforms, to make suggestions to groups of consumers sharing similar characteristics. Under the proposed framework, targeted support is not a personal recommendation and does not trigger suitability requirements under COBS 9 or 9A. The boundary is crossed when the interaction becomes a personal recommendation requiring individual suitability assessment. Staff delivering targeted support must be trained to recognise this line, because the regulatory consequence of crossing it without the corresponding suitability process is a compliance failure, not an administrative oversight.

When Should I Upgrade a Client to Full Advice?

An adviser must stop the simplified advice process and transition to full planning whenever any of the following apply:

• The client's stated need cannot be addressed without assessing their wider financial picture.

• The recommended product involves complexity excluded from the simplified advice scope, such as defined benefit transfers, trust-based arrangements, or complex tax structures.

• The client discloses information during the meeting that reveals a vulnerability marker or foreseeable life change that materially affects suitability.

• The client asks questions that can only be answered through holistic financial planning.

When an upgrade is triggered mid-engagement, the file must document the point at which the transition occurred and the reason for it. Attempting to complete a simplified advice file for a client who required full planning carries higher compliance risk than the upgrade itself.

Request a demo to see how the platform adapts to your firm's existing templates under the new CP26/10 rules, or start a 14-day free trial, no credit card required. Monthly rolling agreement. 30-day money-back guarantee. Annual commitment available with 10% discount.

FAQs

What Are the Key Differences Between Simplified Advice and Targeted Support?

Targeted support is a non-advised service that allows firms to make suggestions to groups of consumers sharing similar characteristics, without delivering a personal recommendation or triggering individual suitability requirements. Simplified advice is a regulated personal recommendation focused on a specific, limited client need, and it carries full suitability and Consumer Duty obligations even though the fact-find is proportionate.

What Products Are in Scope Under CP26/10?

Simplified advice under the proposed framework is expected to be limited to a defined, straightforward transaction. For example, recommending a consumer starts contributing to a workplace pension, or makes a straightforward ISA investment. The FCA's CP26/10 consultation involves consolidating rules in COBS 9 and 9A into a single framework, removing distinctions between advice on products in scope of the Markets in Financial Instruments Directive II, insurance-based investment products and other life policies and pensions. Complex structures including defined benefit pension transfers, trust-based arrangements, and complex tax mitigation strategies are expected to fall outside the simplified advice scope.

How Will Simplified Advice Affect My Current Client Base?

It allows you to offer a lower-cost, compliant service to clients with straightforward, focused needs who are currently over-serviced under a full planning proposition or priced out of regulated advice entirely. Existing full planning clients remain on their current service and are not affected unless you actively reassess their service category.

Can a Simplified Advice Fact-Find Legally Omit Sections of a Standard Fact-Find?

Yes, provided the omitted sections are genuinely irrelevant to the specific recommendation being made and the omissions are documented with a justification in the client file. The FCA's proportionality guidance allows firms to gather proportionate information for the specific recommendation being made rather than requiring a comprehensive fact-find, giving firms the legal basis for a narrower scope where that scope is clearly defined and documented.

When Is the FCA Expected to Finalise the CP26/10 Rules?

The consultation is expected to close in mid-2026. The FCA has indicated it plans to publish a policy statement later in 2026. Firms should begin template configuration, training, and workflow routing preparation before the final rules are published.

Do Consumer Duty Obligations Still Apply Under Simplified Advice?

Yes, fully. Consumer Duty outcomes (products and services, price and value, consumer understanding, and consumer support) apply to simplified advice files, with firms expected to evidence these outcomes under the proportionate framework.

Key Terms Glossary

COBS 9 and COBS 9A: The sections of the FCA Handbook governing suitability assessments for full planning and simplified advice respectively. Under CP26/10, these are proposed to be consolidated into a single chapter, COBS 9C, with unified proportionality expectations.

Proportionate fact-find: A limited-scope fact-find that gathers only the information genuinely necessary to support a focused, simplified recommendation, with documented justification for any sections omitted from the standard template.

Consumer Duty outcomes: The four regulatory standards firms must evidence under FCA supervision: products and services, price and value, consumer understanding, and consumer support. These apply in full to simplified advice files.

Targeted support: A non-advised service allowing firms to make suggestions to groups of consumers sharing similar characteristics, without delivering a personal recommendation and without triggering individual suitability requirements.

Advice creep: A focused simplified advice conversation that gradually expands to cover areas requiring holistic assessment, without the corresponding depth of documentation or client agreement to a broader scope.

SM&CR: The Senior Managers and Certification Regime, which establishes personal regulatory accountability for senior managers across FCA-regulated firms. Simplified advice does not reduce SM&CR obligations for senior managers accountable for advice quality.

COBS: The Conduct of Business Sourcebook, the section of the FCA Handbook that governs how firms interact with clients, including suitability assessment requirements, disclosure obligations, and client communication standards.