What is a centralised investment proposition (CIP)? A 2026 guide for UK IFAs

You're sitting in an investment committee on a Tuesday afternoon. Five of you round the table, two on Teams. The compliance officer raises the question that everyone hoped someone else would raise first: "If the FCA walked in tomorrow and asked to see our CIP, what would we hand them?" Three people look at the Dropbox folder. One person looks at the wall. The senior partner says, "We have one. It just isn't all in one place." That's the moment most firms realise their CIP isn't a document. It's a habit.

The definition, in one paragraph

A centralised investment proposition is a documented, firm-wide framework. It sets out how the firm researches, selects, constructs, monitors and reviews the investment solutions recommended to clients within defined segments. The CIP says who the firm advises, what they're recommended, why those solutions are appropriate for that segment, and howthe firm checks that the answers still hold a year later.

The FCA's original thematic work on this — TR16/1, Assessing Suitability: Research and due diligence of products and services— set the expectation in 2016 and the regulator hasn't softened it since. PS22/9 (the Consumer Duty Policy Statement) made it sharper. PROD 4 in the FCA Handbook then put product-governance obligations on the firms designing and distributing solutions, which folds directly into how a CIP must be run.

CIP vs CRP — different propositions, same logic

A CIP covers accumulation. A centralised retirement proposition (CRP) covers decumulation. The FCA's drawdown thematic findings made it clear that drawdown clients have a different risk profile to accumulating clients — sequence-of-returns risk, the impact of withdrawals on capital, and the longevity question all change the maths — and that a firm advising on drawdown should have a proposition designed for that phase, not a CIP with a pension wrapper bolted onto it.

Many firms now operate both, with shared governance and separate solution sets. The architecture matters: clients moving from accumulation to decumulation should cross a documented boundary, not drift between the two without anyone noticing. We cover that in detail in our piece on CRPs and decumulation strategy.

What a CIP usually contains

There's no FCA-prescribed template. What follows is the structure we see in firms that pass their compliance reviews without follow-up letters.

• Investment philosophy.One or two pages on what the firm believes about markets, risk, asset allocation, active vs passive, and ESG. Specific enough that a paraplanner reading it can predict the firm's answer on most questions.
• Client segmentation.Named segments — accumulator/decumulator, attitude-to-risk band, capacity-for-loss band, ethical preference, complexity (HNW vs mass-affluent vs small-pot). Each segment has a profile a real client could be mapped to.
• Solution set per segment.The investment solutions actually used for each segment. Model portfolio service (in-house or outsourced), multi-asset funds, bespoke DFM mandates, single-strategy funds where appropriate. With named providers and named ranges.
• Research and due-diligence process.Who researches what, against what criteria, using which data sources (Defaqto, Morningstar, FE, the firm's own analytics), how often, and where the records sit.
• Governance.Who sits on the investment committee, who chairs it, how often it meets, what it minutes, and who has authority to add or remove a solution from the CIP. The minutes are evidence the FCA will ask for.
• Ongoing review cadence.The schedule for reviewing each solution against the segment it serves. Annually at a minimum; quarterly for any solution where the firm has reason to suspect drift.
• Exception process.What happens when an individual client doesn't fit a segment cleanly. The CIP exists to make the standard case efficient; it shouldn't force clients into the wrong segment, which is the FCA's shoehorning concern.
• Consumer Duty mapping.Post-2023, each segment's solution set needs to be evidenced against the four outcomes — products and services, price and value, consumer understanding, consumer support — with reference to the target market.

Why CIPs exist — the practical case before the regulatory one

The regulatory case is the one most often cited. Without a CIP, every adviser in the firm is reinventing the recommendation each time. That's expensive, inconsistent and difficult to defend at the point of compliance review. The FCA's preference for documented, repeatable processes is well established. A CIP gives a firm a defensible answer to "why did you recommend this solution to this client?".

The commercial case is the one most often under-stated. A firm with a tight CIP can onboard a new adviser in weeks rather than months. The paraplanning function scales because the standard work is standard. Investment-committee time goes to genuine decisions rather than relitigating which fund to use for a sterling-cash bucket. And the cost of running the proposition — research time, due-diligence licences, fund-manager meetings — gets amortised across the whole client book rather than reinvented per case.

The competitive case is the one almost nobody discusses. Firms with documented CIPs are sellable. A firm with a CIP that the buyer can take over without disruption commands a higher multiple than one where the investment proposition lives in one partner's head. If the partner walks out, so does the proposition. That's a discount.

What a CIP is not

It isn't a marketing document. The version on the firm's website that talks about "tailored, holistic, client-centred wealth management" isn't the CIP. The CIP is the version a paraplanner uses on a Wednesday morning to choose between two recommendations.

It isn't a model portfolio. A model portfolio is a componentof a CIP — the solution the proposition might use for a particular segment. Conflating the two is a category error; a firm can run multiple MPS ranges within one CIP, or use external DFM mandates instead of an MPS at all.

It isn't permission to ignore the individual. The FCA's shoehorning concern is precisely about firms using a CIP to default every client into the same solution irrespective of personal circumstances. The CIP says how the standard case is handled. The exception process says how the non-standard case is handled. Both need to be evidenced.

And it isn't optional once you operate one. The FCA's view, expressed across multiple supervisory publications, is that a firm with a CIP must operate it consistently and review it regularly. A CIP nobody runs is worse than no CIP at all — it's documented evidence the firm doesn't follow its own process.

The Consumer Duty layer on top

Since 31 July 2023 for new products and 31 July 2024 for closed-book products, Consumer Duty has added an outcomes overlay to the CIP. The duty doesn't replace the suitability obligations under COBS 9.4; it sits on top.

In practice this means the investment committee's review cadence now has to include an outcomes assessment per segment: are the solutions producing the outcomes the segment was designed to receive? Cash-flow needs being met for decumulation segments; growth being delivered on a horizon appropriate to accumulation segments; fees being justified against the value the segment receives. The annual fair-value assessment under PRIN 2A.4 is part of this. The board-level annual report on consumer outcomes is the other part.

Firms that pass Consumer Duty reviews are the ones that wired the outcomes work into their existing investment-committee process rather than building a parallel Consumer Duty function. The CIP is the natural home for that work.

How an integrated platform fits

The mechanical problem with running a CIP is the volume of evidence required. Every solution recommendation generates a trail — the research, the due diligence, the suitability fit to segment, the minute of the investment committee that approved the solution, the ongoing review, the outcomes assessment. Held across five systems, that trail takes paraplanner time to assemble whenever compliance asks.

An end-to-end pipeline — fact-find through proposal through ongoing review, with the segmentation logic and the solution set baked in — collapses the assembly time. Wealth Analyticasits at the proposal-and-monitoring end of that pipeline. The CIP itself is a firm document; the platform's job is to make running it cheap enough that the firm actually does, rather than treating the CIP as a thing that gets dusted off twice a year.

Where to go next

If you're building or rebuilding a CIP, the practical sequence is segmentation first, solution set second, governance third, documentation fourth. The order matters: governance is impossible to design if you haven't first decided who you serve and how. We've written that sequence up in detail in how to build a CIP.

If the question is whether to run the CIP in-house or outsource the investment work to a DFM under your governance, that's a different decision with real trade-offs. We cover it in in-house CIP vs outsourced DFM.

If you already have a CIP and the question is whether it would survive an FCA review on shoehorning, the practical checklist sits in FCA shoehorning guidance.