Targeted support is live, and a firm that won't apply for it should still record why

Targeted support went live on 6 April 2026. Our explainer on the regime takes the view that most IFA firms won't apply for it, and for many that will be the right commercial call. I'd still want the decision written down.

What the regime is

The rules are in the FCA's policy statement PS25/22. Near-final rules were published on 11 December 2025. The FCA Board confirmed them as final on 26 February 2026, firms could apply for permission from 2 March 2026, and the regime went live on 6 April 2026. The FCA's own estimate, on that page, is that around 23 million consumers are currently underserved by the markets for advice and guidance.

Targeted support lets a firm offer suggestions designed for groups of consumers with common characteristics. The FCA's Advice Guidance Boundary Review page gives two examples: suggesting an alternative sustainable withdrawal rate to a consumer drawing down their pension unsustainably, or suggesting that a consumer holding excess cash invests it in an ISA. It comes with its own conduct standards, alongside the Consumer Duty.

It's a new specified activity. A firm needs the permission to do it, applications go through Connect, and the FCA's pre-application support service is open to firms planning to apply.

Why a firm that won't apply still has work to do

Three reasons, and they're different in kind.

Governance comes first. A decision not to use a new permission is still a decision, and a board that considered it should be able to show that it did. A short note does the job: what the firm looked at, why it concluded the regime doesn't fit its proposition today, and when it will look again. If a new compliance lead, an acquirer or the regulator asks in two years, the answer's on file.

Then there's the boundary itself. Plenty of IFA firms send group communications: a tax-year-end email, a note to everyone in drawdown, a message to clients holding a lot of cash on platform. Most of that is information, and fine. But a message that suggests a course of action to a defined group of people is worth reading again now that there are three places it could land rather than two, because general information, targeted support and a personal recommendation each carry different obligations and the wording of a single email can move it from one to another. Which side a given message falls on depends on its wording and the circumstances. That's one for your compliance support, not a rule of thumb.

And the people you can't serve. Some prospects a firm turns away because full advice isn't economic for them may now be offered targeted support elsewhere, by a platform, a pension provider or a bank. That doesn't oblige an IFA to do anything. It's still worth knowing where those people are likely to end up, and whether the firm's signposting wording still reads sensibly.

What to check on Monday

• Is there a written, dated record of the firm's decision on targeted support, with a review date?
• Has someone reread the last six months of group client communications with the new boundary in mind?
• Does the firm's process for prospects it can't serve say where they're pointed, and is that still accurate?
• If the firm is considering applying, has it looked at the FCA's pre-application support service before drafting anything?

None of this takes long. So it tends not to get done.

What's still moving

The regime is new and the rest of the boundary review isn't finished. The FCA said on its review page that it would consult on simplifying its advice rules in early 2026, and it describes simplified advice as a possible stepping stone between targeted support and fuller advice. A position recorded now is a starting point you'll revisit. Which is a good reason to date it.

The sources here are the FCA's PS25/22 page and its Advice Guidance Boundary Review page. Whether any of this applies to a particular firm depends on its permissions, proposition and client base.