FCA compliance for advisers has shifted from "did you follow the rules?" to "can you prove your clients got good outcomes?" The Consumer Duty made outcomes the test, and in 2026 the FCA is supervising on exactly that — evidence that your controls are working and improving over time, not just that they exist. Here's what that means in practice for an IFA or advice firm, and how to stay on the right side of it.
- The Consumer Duty is the centre of gravity — you must evidence good outcomes across four areas, not just have policies. The FCA is consulting in H1 2026 on how the Duty applies across distribution chains.
- SM&CR is the accountability mechanism — named senior managers are personally responsible for embedding the Duty. The FCA is reviewing SM&CR in H1 2026 to reduce the burden.
- Suitability and ongoing advice remain front-line risks — clients paying for ongoing service must actually receive it.
- The FCA expects records and management information (MI) that show outcomes are improving over time.
Who this applies to
If you're a directly authorised adviser firm — or operate through an appointed representative arrangement — you sit fully within FCA supervision. The Consumer Duty, SM&CR, the suitability rules (COBS) and the complaints rules (DISP) all apply, and the FCA increasingly judges you on the outcomes your clients actually experience.
The Consumer Duty — the centre of gravity
The Duty asks you to deliver good outcomes for retail clients across four outcomes:
- Products & services — designed for an identified target market.
- Price & value — clients get fair value for what they pay (a live issue for ongoing-advice fees).
- Consumer understanding — communications that clients actually understand, evidenced by testing.
- Consumer support — support that's as easy to use as the sales process.
Underpinning these are the cross-cutting rules: act in good faith, avoid foreseeable harm, and enable clients to pursue their financial objectives. The 2026 emphasis is evidence — the FCA wants to see that your controls are working and outcomes are improving, with consumer-understanding moving "from good intentions to regulator-ready evidence."
SM&CR — personal accountability
The Senior Managers & Certification Regime is how the FCA holds individuals accountable for embedding the Duty. That means clear Statements of Responsibilities, certified staff assessed as fit and proper, and conduct rules trained and lived across the firm. The FCA, with HM Treasury and the PRA, is reviewing SM&CR in H1 2026 with the stated aim of cutting the regulatory burden — but accountability isn't going away; it's being streamlined.
Suitability & ongoing advice
Two perennials drive most enforcement and complaints: suitability (advice and suitability reports that genuinely match the client's needs, objectives and risk capacity) and ongoing advice services (clients paying an ongoing fee must actually receive the reviews they're paying for). If you charge for an annual review, you need to be able to prove it happened — this is squarely in the FCA's price-and-value sights.
Where firms get caught
- Consumer Duty treated as a one-off project, not an ongoing, evidenced process.
- Ongoing-advice fees collected without documented annual reviews.
- Suitability reports that don't clearly justify the recommendation.
- Thin MI — no data showing outcomes are actually improving.
- SM&CR paperwork that's out of date or not matched to what people really do.
A simple plan to get ready
Start with a clear-eyed view: our free 2-minute IFA / adviser self-check scores you against the FCA's expectations and surfaces your gaps on the spot. Then make sure your Consumer Duty evidence, suitability files and SM&CR records are current and joined-up (our own-forever document suites are built for this), put real MI behind your outcomes, and rehearse with a compliance review before the FCA asks.
Frequently asked questions
Is the Consumer Duty a one-time exercise?
No. It's an ongoing obligation to deliver and evidence good outcomes. In 2026 the FCA expects data showing your controls work and outcomes are improving over time.
Is SM&CR being scrapped?
No. The FCA is reviewing it in H1 2026 to reduce the burden, but individual accountability for outcomes remains.
What's the biggest ongoing-advice risk?
Charging an ongoing fee without evidence the annual review was actually delivered — a direct price-and-value concern under the Duty.
What should I prioritise first?
Run the free self-check, then shore up Consumer Duty evidence and your ongoing-advice review process — that's where the FCA is looking hardest.