CP26/10 — simplifying pensions and investment advice rules: an IFA explainer

The Advice Guidance Boundary Review has two outputs. One is the new Targeted Support permission going live on 6 April 2026, which we covered in a separate piece. The other is the refresh of Simplified Advice, currently under consultation in CP26/10. Targeted Support gets the headlines because it's the genuinely new permission. CP26/10 is the more practically important of the two for the typical UK IFA.

Here's what the paper is doing, what it's proposing, and what an IFA partner should do about it.

What CP26/10 is consulting on

The paper covers three connected questions.

First, what should the suitability framework look like for advice that is genuinely simpler than full holistic advice? The current COBS 9 suitability regime evolved to handle complex multi-objective planning. Applying the same process to a single-product, single-objective decision adds cost without adding protection.

Second, where should the boundary sit between Simplified Advice and full advice? The FCA's working assumption is that Simplified Advice covers decisions with limited scope — a single ISA, a pension contribution decision, a one-off lump-sum investment — for consumers below a defined affluence threshold and with reasonably straightforward financial circumstances. Above the threshold or beyond the scope, full advice applies.

Third, how does Simplified Advice interact with Targeted Support and with information-and-guidance? The four regimes have to sit cleanly on a ladder, with a clear path for consumers between them as their needs grow.

The headline proposals

From CP26/10, the proposals likely to land in the final policy statement:

A narrower fact-find.The Simplified Advice fact-find collects only what's needed to give the specific recommendation in scope. The current full fact-find — covering all financial circumstances, all dependents, all assets, all liabilities — is disproportionate when the decision in front of the consumer is "should you contribute the £3,000 you have to an ISA or a pension".

A standardised attitude-to-risk approach.The paper proposes that Simplified Advice firms can use a standardised ATR methodology rather than each firm defining its own. The methodology is published, transparent, and consistent across providers — which makes outcomes comparable and reduces the cost of the suitability step.

A simpler suitability report.A two-page Simplified Advice suitability report covering the decision in scope, the reasoning, the alternatives considered, and the explicit acknowledgement that the advice is limited in scope. Not the 20-page full report. The consumer needs to know what they bought and why, and have it on the record. They don't need a holistic-advice document for a single-product decision.

Proportionate ongoing-service obligations.If a Simplified Advice firm doesn't offer ongoing service, the regime makes that explicit and reduces the regulatory overhead accordingly. The consumer is told, at the point of sale, that they're getting a one-off recommendation and that they will need to come back if their circumstances change.

Charging structures aligned to the scope.The expectation is that Simplified Advice can be charged at a fixed fee — typically a low three-figure amount per decision — rather than an ongoing percentage. This matters for the economics of serving lower-AUM consumers.

The interaction with Targeted Support

Targeted Support gives a consumer a segment-level ready-made suggestion based on limited information. Simplified Advice gives a consumer a personal recommendation, narrower in scope than full advice but bespoke to them. The progression is:

1. Information & guidance — no recommendation, no individual conclusion
2. Targeted Support — ready-made suggestion based on segment placement, not bespoke
3. Simplified Advice — bespoke personal recommendation, narrower scope and proportionate process
4. Full holistic advice — bespoke personal recommendation, full scope and full process

A consumer's journey can move through these as their needs grow. The Targeted Support customer who outgrows the segment moves to Simplified Advice. The Simplified Advice customer who accumulates wealth moves to full advice. The regulator's intention is that consumers can find a regime that fits their need at every stage.

What an IFA firm should do

Three responses, depending on how the firm currently serves lower-AUM consumers.

If the firm currently doesn't serve lower-AUM consumers — turns away anyone below a £100k or £250k threshold — CP26/10 is potentially commercially significant. Simplified Advice may make the economics work for serving that population for the first time. The firm should respond to the consultation with the practical issues it can see, and start planning capability for an eventual Simplified Advice service if the rules land in a usable shape.

If the firm already serves lower-AUM consumers under a streamlined version of its full-advice process, CP26/10 is an opportunity to consolidate that process onto a regulator-defined framework rather than a firm-by-firm interpretation. The standardised ATR and the simplified suitability report could reduce the firm's per-case cost.

If the firm focuses exclusively on higher-AUM full-advice clients and has no interest in lower-end provision, CP26/10 still matters as a directional signal. The regulator is signalling that proportionality is the principle. The same logic that makes a two-page suitability report acceptable for Simplified Advice will, over time, influence what good practice looks like for the simpler decisions inside a full-advice relationship.

How to respond to the consultation

The consultation period runs through 2026. Responses can be submitted via the FCA's website. The responses that land best are the ones that engage with the practical edges — what works, what doesn't, what's ambiguous, what creates unintended consequences. Generic "we support this proposal" or "we oppose this proposal" responses are less useful than specific cases.

An IFA firm responding should aim to bring at least one real worked example: a current client, anonymised, whose advice could in future fall under Simplified Advice; what would change for them under the proposed rules; whether the consumer outcome improves, stays the same, or deteriorates. The FCA has been explicit that worked examples carry weight.

Timing for go-live

Assuming the consultation closes on schedule and the policy statement is published in the second half of 2026, Simplified Advice rules under CP26/10 are likely to go live in 2027. Firms wanting to offer the service from the first day will need to plan for technical capability, staff training, and the FCA application process during 2026. Firms watching from the sidelines have time to see how the first wave goes before committing.

Where Wealth Analytica fits

The technology side of Simplified Advice is, in many ways, the easier part. A narrower fact-find, a standardised ATR, a two-page suitability report and a fixed-fee charging structure are all things a single-platform lead-to-proposal pipeline handles cleanly. Wealth Analyticais built around exactly that workflow shape — so a firm planning a Simplified Advice service will find the platform side ready when the rules go live. The hard parts of Simplified Advice are governance and target-market discipline. Those are organisational, not technical.