The advice gap has been described for a decade and structurally unchanged for most of it. That stopped being true this year, and this morning gave us the first evidence that the change is reaching actual consumers rather than sitting in a policy statement. Royal London told Professional Adviser that thousands of customers have now been through its targeted support journey, that satisfaction was high among both those who invested and those who concluded it was not for them, and that it intends to extend the service into pensions. Two days earlier, the same title reported that Hargreaves Lansdown plans to launch its first targeted support use case in the coming months. This is no longer a consultation. It is a market.
Accountants should welcome it, and then read the small print, because the small print is where the professional implication sits. Targeted support works by making suggestions to groups of customers who share characteristics. That is its power — it is how it reaches millions of people at a cost that makes sense — and it is also its one hard limit. Segment logic is only as good as the data the provider holds, and a provider holds product data. It does not hold a client’s corporation tax timetable, their personal guarantee, their deferred consideration, or the fact that the business is under offer. You do.
What actually changed, and when
The Advice Guidance Boundary Review is a joint initiative between HM Treasury and the FCA, and targeted support is the part of it that has now landed. The FCA published policy statement PS25/22 setting out near-final rules on 11 December 2025, and the FCA Board confirmed those rules as final on 26 February 2026. Applications for the new permission are being accepted through Connect, and the regulator has said that firms arriving at the gateway ready and organised would be authorised swiftly after the provisional April 2026 go-live. Royal London was among the first through, launching in April via its stocks and shares ISA.
The FCA’s own framing of the prize is worth quoting accurately, because it is larger than most of the coverage suggests. At least 18 million people could be offered extra help with their investments and pensions over the next decade. The regulator’s supporting data is blunt: around 7 million UK adults hold £10,000 or more in cash savings and may be missing out on the benefits of investing across their lifetimes; fewer than 1 in 10 obtain regulated financial advice; and nearly 1 in 5 investors turn to social media for help making decisions. Sarah Pritchard, the FCA’s deputy chief executive, called the regime “gamechanging”.
Set that against the shape of the advice market the lang cat recorded in its State of Advice 2025 report — 9% of UK adults having taken advice, an average new client portfolio of £411k, an average client age of 59, and fewer than 5,000 IFA businesses serving the whole country — and the logic of the reform is obvious. A market with those economics was never going to reach 18 million people one financial plan at a time.
What targeted support can and cannot do
The distinction that matters professionally is precise, and it is worth getting right before a client asks. Under targeted support, consumers receive suggestions, but those suggestions are expressly not based on a full, in-depth individual assessment. Firms must make sure suggestions are suitable and should only offer them where doing so puts the consumer in a better position. It is a regulated activity with its own conduct standards, sitting underneath the Consumer Duty.
The FCA’s own illustrations show the shape clearly. A firm might suggest an alternative, more sustainable withdrawal rate to a consumer drawing down a pension too quickly. Or it might suggest that a consumer holding excess cash in an account considers an ISA. Both are sensible. Both are also derived entirely from what the provider can observe inside its own systems: a balance, a drawdown rate, an age, a product mix.
Targeted support knows which segment your client is in. You know why they are in it.
The worked example: the £180,000 that is not excess cash
Consider a client who runs a profitable services company. Personally, they hold £180,000 in a savings account. A targeted support engine looking at that balance sees a textbook case: a substantial cash holding, no investment engagement, an obvious suggestion to consider an ISA. On the segment’s own terms, the suggestion is sound.
You know four things the engine does not. £62,000 of that balance is earmarked for a personal tax bill in January, because they took a large dividend in the year to cover a shortfall elsewhere. £45,000 is the deposit on a commercial unit they are buying in the spring, having decided to stop renting. £30,000 is a genuine emergency reserve for a household with a single earner and no sick pay. That leaves roughly £43,000 that is arguably surplus — and the picture changes again once you factor in that the company itself is sitting on retained profit that would be a far better source of long-term funding through an employer pension contribution than personally-taxed cash.
Nothing here makes the targeted support suggestion improper. It makes it incomplete in a way that only someone holding the whole picture can detect. And the risk is not that the client acts on it recklessly — it is subtler than that. The risk is that the client receives a credible, well-designed prompt from an authorised firm, treats it as the answer, and quietly closes a question that was worth opening properly. A prompt that produces false completion is harder to spot than one that produces an obvious error.
The four client situations where segment logic is most likely to mislead
These are the ones worth having in mind, because in each case the accountant sees the disqualifying fact and the provider structurally cannot.
- Committed cash that looks like surplus cash. Corporation tax and personal tax liabilities, VAT quarters, property deposits, deferred consideration instalments, dilapidations provisions. All of it looks identical to idle money from the outside.
- Wealth held outside the provider’s view. The client whose dominant asset is shares in their own trading company, or commercial property held personally, or a director’s loan owed to them. A pension suggestion calibrated to their visible assets is calibrated to a fraction of their position.
- A dated event in the near future. A sale under offer, a retirement date, a lease expiry, a shareholder buyout. A sustainable withdrawal rate calculated without knowing that a seven-figure completion lands in nine months is a reasonable answer to the wrong question. This is the ground covered in our note on why the planner belongs in the deal team.
- Structural constraints on what the client can actually do. Personal guarantees, restrictive bank covenants, shareholder agreements, an existing charge over an asset. Constraints do not appear on a platform balance.
What this changes about the year-end conversation
Very little, in one sense — the signals that matter are the same ones as before, and they are already in front of you. Our note on the six signals already sitting in your client file sets out what to look for. What has changed is the sequence. Previously, an unadvised client with idle cash was likely to do nothing at all, and the conversation could wait until someone raised it. Now that client will increasingly be prompted by their provider first, and will arrive at the year-end meeting having already formed a view.
That is a meaningful shift in who speaks first. It argues for making the cash question explicit rather than incidental — asking what each material balance is actually for, and recording the answer — so that when a prompt arrives, the client already understands why their situation is not the standard case. It costs a question, not a service line.
One thing to do this week
Run a single filter over the client list: clients aged 55 or over, with a dated event inside the next 24 months, or a cash balance that is materially committed. In most practices that is a short list — a page, not a spreadsheet. Those are the clients most likely to be prompted and least likely to be well served by a segment-level answer, and the only thing required is that somebody in the firm knows who they are before the prompt arrives. Where a client genuinely needs regulated advice, that remains work for an authorised adviser rather than the practice; the clean division of responsibility is set out in our note on who does what.
What is still uncertain
Two things, and both should be stated plainly rather than assumed. First, the take-up reported so far is a single provider describing its own early results in its own results commentary, covering an ISA proposition launched in April. Thousands of customers is a real number and a genuinely encouraging one, but it is not yet independent evidence about how targeted support performs at scale or across pensions, which Royal London has said is next. The regime is roughly four months old.
Second, the wider reform is not finished. The FCA has said it will consult on simplifying and consolidating its advice rules, including clarifying the flexibility that already exists for more focused, simplified forms of advice. Simplified advice is the piece that sits between targeted support and full holistic planning, and it is the piece most likely to affect how owner-managed business clients are served. Until those rules are consulted on and settled, the middle of the market remains partly undefined. That is worth watching rather than waiting for.
Common questions
Does targeted support mean clients no longer need a financial planner?
No, and the FCA has not presented it that way. Targeted support is designed to reach the roughly 18 million people the regulator expects could be offered help over the next decade — people who currently get nothing, not people already receiving holistic advice. Its defining limitation is structural: suggestions are made to groups of customers with common characteristics, and are explicitly not based on a full, in-depth individual assessment. For a salaried employee with one pension and some cash, that is a large improvement on silence. For an owner-managed business client whose wealth sits inside a trading company, the segment is the least interesting fact about them. Both things are true at once.
Can an accountancy practice offer targeted support itself?
Not without applying for it. Targeted support is a new specified activity requiring its own FCA permission, applied for through Connect, and the regime is aimed squarely at pension providers, platforms, banks, wealth managers and similar firms holding customer products and data. It is not a route by which an accountancy practice can begin making investment or pension suggestions. Nothing about the new regime changes what an unregulated practice may do, which remains substantial: noticing a client circumstance, asking whether it has been addressed, and introducing the client to someone authorised. The boundary between observing a situation and recommending a course of action is exactly where it was before April.
How would I know whether a client has received a targeted support suggestion?
Usually because they mention it, and often not in those words. It will surface as a passing remark: their pension provider suggested a different withdrawal rate, their platform prompted them about cash sitting in the account, their bank flagged that they could be doing something else with a balance. The phrase targeted support is regulatory vocabulary and consumers are unlikely to use it. What you will hear is a client who has been given a number by somebody and wants to know whether it sounds right. That question is the signal worth catching, because it usually arrives without any of the context that would determine the answer.
Is a targeted support suggestion regulated, and can a client complain about it?
Yes on both counts. Targeted support is a regulated activity requiring FCA permission, it carries its own conduct standards, and it sits underneath the Consumer Duty. Firms must ensure suggestions are suitable and should only offer them where doing so puts the consumer in a better position. The FCA published joint statements with the Financial Ombudsman Service and the Information Commissioner covering complaint handling and customer communications. So a client is not unprotected. But protection is not the same as precision. A suggestion can be entirely compliant, suitable for the segment, and still wrong for a particular client whose circumstances the provider was never in a position to see.
Which clients should a firm look at first?
The ones where the segment and the reality diverge most sharply. Start with clients holding significant cash whose purpose is already committed — a corporation tax liability, a property deposit, a deferred consideration payment. Then clients aged 55 and over with a material event in the next two years, particularly a sale, a retirement date or a lease expiry. Then clients whose personal balance sheet is dominated by an asset no provider can see, such as shares in their own trading company or commercial property held personally. These are not clients who need protecting from targeted support. They are clients for whom a segment-level answer is a starting point rather than a conclusion.