Targeted Support — the FCA's new April 2026 regime for UK IFAs

On 6 April 2026 the FCA's Targeted Support regime becomes a live permission an authorised firm can hold. It is the most material change to the regulated-advice perimeter since RDR. For most IFAs it will not change the day-to-day workload of advising existing clients. For some firms — particularly those running an embedded service for an SIPP provider, a bank, a workplace-pension provider, or a wealth manager with a large self-directed book — it changes what's commercially possible.

This piece is the IFA-facing read on the new regime. It assumes you already know the bones of the Advice Guidance Boundary Review (AGBR) the FCA has been consulting on since the December 2023 discussion paper. What it adds: the practical edges, the application question, and what to do on the Monday after the rules go live.

What Targeted Support actually is

The simplest way to describe Targeted Support is by comparing it to what came before. Until 6 April 2026 a firm interacting with a consumer about an investment decision sat in one of two regulated states. Either the firm was providing "information and guidance" (factual, no recommendation, no suitability obligation) or it was providing a personal recommendation (a regulated activity under Article 53, full COBS 9 suitability obligations, paid for and chargeable).

Targeted Support inserts a third state.

It permits a firm to make a "ready-made suggestion" — language the FCA uses deliberately — to a consumer, based on limited information about that consumer and the segment they belong to. The suggestion is not bespoke to the individual. It is a product or course of action the firm has pre-defined as suitable for consumers who match a specified segment. The consumer tells the firm enough to be placed into the segment. The firm then tells the consumer what people in that segment typically do, and offers them the means to act on it.

Two examples the FCA has used in its papers to illustrate the regime:

• A SIPP provider notices a customer is approaching retirement with a 95% cash allocation. Under Targeted Support it could say: "Customers in your situation typically reduce cash to around 30% and shift the balance into a diversified portfolio. Here's a ready-made option to do that."
• A workplace-pension provider sees a member approaching age 55 with a default-fund allocation. It could say: "Members planning to access their pension at 55 typically move to our lifestyle option. Here's how to switch."

Neither is a personal recommendation. Neither is information and guidance. Both are Targeted Support.

How it sits next to Simplified Advice and full advice

The AGBR introduces (or formalises) three distinct service levels. Targeted Support is one. The others are Simplified Advice — a streamlined personal-recommendation regime for straightforward investment needs typically under a £85,000 threshold — and the existing full holistic-advice regime, which doesn't change. Think of it as a ladder.

• Information & guidance— no recommendation, no suitability, no individual conclusion. Unchanged.
• Targeted Support— segment-level ready-made suggestions. New from 6 April 2026.
• Simplified Advice— personal recommendation, narrower scope and a lighter suitability process than full advice. Refreshed under AGBR.
• Full holistic advice— full personal recommendation, full COBS 9, what most IFA firms do today. Unchanged.

The point of the ladder is that consumers without the means to pay for full advice — currently estimated at most of the UK adult population with savings — should have somewhere to go that isn't pure execution-only. The FCA has been explicit that closing the "advice gap" is the policy objective.

Who can hold the permission

Targeted Support is a new regulated activity. To do it, an authorised firm needs the relevant permission on its FCA Part 4A authorisation. Firms apply via a Variation of Permission. The application is not automatic — the FCA will assess the firm's proposed scenarios, its segmentation methodology, its consumer-outcome monitoring, and its Consumer Duty governance before granting.

A small caveat: the rules don't require an IFA firm to apply. An IFA giving personal recommendations to its existing client book under full advice doesn't need Targeted Support permission to keep doing that. The permission only becomes relevant if the firm wants to do something it currently can't — pre-segment a non-client population, offer them ready-made suggestions, and convert some of them into clients on a lighter-touch service.

From the practitioner conversations we've had since the AGBR consultation closed, three firm types are most likely to apply: workplace-pension providers and master trusts looking to engage at-retirement members, banks and platforms with self-directed customers sitting on uninvested cash, and ambitious IFA firms with a digital arm aimed at a younger or lower-AUM segment they can't currently serve profitably under full advice.

The application — what the FCA wants to see

The Variation of Permission application for Targeted Support requires materially more than a tick-box. The FCA's published expectations (in PS25 and the supplemental SUP rules) cover the following ground.

Defined consumer segments.For each Targeted Support scenario the firm proposes, it must define the consumer segment to which the ready-made suggestion will be offered. Segment definitions need to be precise enough that a consumer either does or doesn't fit. "Customers approaching retirement" is not a segment. "Customers aged 55–60, with a defined-contribution pot between £30,000 and £150,000, with no other private pension provision, who have indicated they intend to access their pot within five years" is.

Pre-defined suggestions per segment.The firm specifies, in advance, the suggestion that will be offered to consumers placed into each segment. The suggestion has to be defensible as appropriate for the segment in aggregate, even though it will not be tailored to the individual.

Segmentation methodology.How the firm decides which segment a consumer belongs to — what data it collects, what questions it asks, how it handles cases that fall outside any defined segment.

Consumer-outcome monitoring.Targeted Support sits under the Consumer Duty. The firm must monitor outcomes for consumers who acted on each ready-made suggestion, at the segment level, and have a process for redesigning segments or suggestions when outcomes deteriorate.

Senior Manager accountability.A named senior manager owns the Targeted Support function under SMCR, with documented responsibilities. The board (or equivalent) reviews Targeted Support outcomes at least annually.

And — this matters — the firm must explain to each consumer entering Targeted Support that they are not receiving advice. The disclosure has to be clear, prominent, and timed before the consumer acts on the suggestion. Burying it in a terms-of-service footer is explicitly out of scope.

What changes inside an IFA firm on 6 April 2026

For a typical IFA firm with 200–1,500 client households, nothing has to change on day one. Your full-advice service continues under COBS 9 as it always has. Your suitability obligations to existing clients don't shift.

Three things are worth doing in the first quarter after go-live regardless of whether the firm intends to apply.

First, document your position. A short internal memo — two pages is enough — stating that the firm has assessed Targeted Support, decided not to apply (or to apply, with the application in progress), and confirming that existing client interactions remain under full personal recommendation. The Consumer Duty board report for the year will want to reference it.

Second, look at any non-client interactions you do today. The triage call you offer to website enquirers, the initial meeting before a client signs on, the workplace-pension seminar your firm runs for a corporate client's staff — all of these sit in the information-and-guidance zone today and stay there under the new rules, provided you don't drift into segmented ready-made suggestions. If you do, that's now Targeted Support and you'd need permission to do it.

Third, think about the consumers you currently turn away. Every IFA firm has a minimum-AUM threshold below which the maths of full advice doesn't work. Targeted Support is the regime designed for that population. If the firm has a strategic interest in engaging the next generation of clients — adult children of existing clients, for example — Targeted Support is the mechanism the regulator is offering to do it.

What the AGBR is signalling for the next phase

The 6 April 2026 implementation is the start of a longer trajectory, not the end of it. Two signals are worth tracking.

The FCA has been clear that Simplified Advice will be refreshed alongside Targeted Support. The consultation paper that followed PS25 — CP26/10 — runs through 2026 and shapes how Simplified Advice will work in practice. We've covered CP26/10 separately in our companion piece. For most IFA firms it's the more relevant of the two reforms: it makes the personal-recommendation regime more efficient for smaller portfolios.

And the Consumer Duty year-2 outcomes-monitoring requirements continue to apply across all four service levels. Targeted Support isn't an escape from Consumer Duty — it's a regime that sits firmly under it. We've written separately on what year-2 outcomes monitoringlooks like in practice.

A practical decision tree

For an IFA firm deciding whether to apply for the permission, the questions are these.

• Is there a population we could engage commercially under Targeted Support that we can't engage profitably today under full advice? If no, don't apply.
• Do we have the technical capability — segmentation engine, ready-made-suggestion catalogue, outcome-monitoring infrastructure — to run the service? If no, partner with a provider that does, or hold off.
• Do we have a senior manager willing to own it under SMCR? If no, don't apply.
• Does the firm's Consumer Duty governance extend cleanly to a segment-level outcome-monitoring discipline? If no, fix that first.

The right answer for most independent UK IFA firms with under thirty advisers is: not now. Watch what the first wave of permission-holders learns, and consider in 2027 or 2028 once the regulatory perimeter has bedded in.

Where Wealth Analytica sits

Wealth Analytica is a technology platform. We don't hold a Targeted Support permission and we don't intend to apply for one. What we do provide is the underlying infrastructure — the segmentation, the portfolio analysis, the proposal generation, the Consumer Duty outcome-monitoring — that an IFA firm holding the permission can use to run the service. If you are considering an application, the platform side is one of the easier parts to solve. The hard parts are the governance, the consumer-outcome discipline, and the senior-manager accountability. Those are organisational decisions, not software decisions.