An Equity & General adviser with a client

What simplified advice would mean for a business owner

A narrower, cheaper advice service brings regulated advice within reach of clients who have never had it. That is the aim of the FCA's proposals and the reason advisers are interested in them.

8 min read · Altro Partners, by Equity & General

Reacting to

Six in ten advisers are considering simplified advice — Money Marketing, 7 September 2026

A narrower service asks the client for fewer facts. For a salaried client with a workplace pension and an ISA, the personal facts are the whole picture, and for a client who owns a limited company they are not. The facts that change the answer, the company's cash, its tax reserves, the director's loan account and any sale under discussion, sit in the company's accounts, and the accountant holds them.

What the research found

Money Marketing reported on 7 September 2026 that 59% of the advisers in a Vanguard survey said they were likely to adapt their advice models to offer simplified advice to some clients. The survey covered about 200 UK advisers and was carried out as part of Vanguard's Powering your adviser business towards 2030 roadshow.

59%
of the advisers surveyed said they were likely to adapt their advice models to offer simplified advice to some clients
200
UK advisers covered by the survey, carried out as part of a Vanguard roadshow

Vanguard survey, reported by Money Marketing, 7 September 2026.

Gillian Hepburn, Vanguard's head of UK adviser solutions and sales, said:

“We expected advisers to be interested, but the level of openness was higher than anticipated.”

Two further details are in the reporting. Firms focused on long-term growth were the most receptive, and firms preparing for succession or a sale were the least, so the change will arrive unevenly across the advisers your clients meet. Professional Adviser, covering the same research the same morning, reported that the coming inclusion of unused pensions in the estate for inheritance tax is driving the interest, in particular around wealth transfer.

The figure is a statement of intent from about 200 advisers. No simplified advice service can be launched until the FCA finalises the rules.

What simplified advice is

Simplified advice is a set of proposals in an FCA consultation, CP26/10, Simplifying the pensions and investment advice rules, which opened on 25 March 2026 and closed on 22 May 2026. The FCA has said it will publish feedback and a policy statement once it has reviewed the responses. As at 7 September 2026 none has been published and no implementation date has been set.

The FCA is consulting on consolidating the suitability requirements in COBS 9 and COBS 9A into one set of rules; on replacing the requirement to consider “necessary” information with an expectation that advisers consider “sufficient” information when assessing suitability; on clarifying that firms need not always assess a customer's knowledge and experience where the product's target market includes clients with no experience; on a single “attitude to risk” concept, with confirmation that firms need not use complex tools or detailed questionnaires to assess it; and on replacing the annual suitability review with periodic reviews based on clients' needs.

Simplified advice is a different thing from targeted support, which has been in force since 6 April 2026 and which we covered in targeted support is live. Targeted support is not advice: a firm identifies a group of people with common characteristics and makes a suggestion to the group, without assessing suitability for any individual. Simplified advice would be advice. It would produce a personal recommendation with a suitability assessment behind it, over a narrower set of facts.

How much information the adviser needs

Under the current rule an adviser must obtain the information necessary to assess suitability. Under the proposal, the adviser must consider sufficient information. The duty stays with the adviser in both cases. What changes is the reference point: sufficiency is judged against the scope of the service, so a narrow service can be advised on a narrower set of facts.

The consequence is that scope carries more weight. An adviser asks about what falls inside the service and the client answers those questions, so a fact outside the scope is not raised and nobody has done anything wrong.

A narrow service and the company’s cash

Illustration, using a made-up client. A client is 61 and the sole director and shareholder of a trading company. She takes a salary of £12,570 and about £40,000 in dividends. She has three personal pensions from earlier employments, worth about £210,000 between them. The company's bank account shows £340,000. She uses a narrow-scope service to consolidate the three pensions into one. On the facts that service asks for, her age, the three pensions, her income, her timescale and her attitude to risk, the recommendation is a sound one.

Her accountant knows five things the fact-find had no reason to ask.

The company could make the pension contribution instead

An employer contribution is paid out of company profit and reduces the profit charged to corporation tax: 19% on profits up to £50,000, 25% on profits over £250,000, with marginal relief between (gov.uk, Corporation Tax rates). Her own contributions are limited by her £52,570 of relevant earnings; the company can contribute up to the £60,000 annual allowance (gov.uk, Tax on your private pension contributions).

The £340,000 is not all available

Part of it is the next VAT return and the corporation tax due nine months after the year end. The accountant knows which part is uncommitted. The cash question covers this.

The director's loan account has a balance

Whether it is in credit or overdrawn changes what the cheapest available money is.

She has spoken to a buyer

A sale under discussion moves her retirement date, and the retirement date is the input on which the timescale and risk questions rest. The joined-up exit covers this.

Her death benefit nominations matter more from April 2027

For deaths on or after 6 April 2027 unused pensions count in the estate for inheritance tax (Finance Act 2026), which is the change driving the interest in simplified advice. When the pension joins the estate covers it.

None of that makes the consolidation advice wrong. Each of the five facts would have come up in a full engagement, and all five are in her accountant’s files.

What it changes at the year-end meeting

An accountant is not being asked to assess a recommendation or to acquire a permission. The change is that “I've sorted my pensions out” can now mean advice on a narrow question, and the accountant only knows which by asking.

The question is about scope: what were you asked about? If the answer includes nothing about the company, the accountant knows something the adviser does not. With the client's agreement, the accountant passes the company-side facts to the adviser. The adviser, who holds the permissions, decides what they mean and makes the recommendation. Who does what sets out the split. The client's agreement is required: passing a client's financial information to a third party without it is a data protection matter.

Two things to do this week

  1. Name the clients whose company changes their personal answer. The ones with retained cash above what the business needs, a director’s loan account with a significant balance, a personal pension contribution the company could make instead, or a sale conversation that has started. Those are the clients for whom a narrow-scope service answers a narrower question than the one they have.
  2. Agree the one question the practice asks. When a client says they have taken advice, the practice asks what the advice covered and writes the answer down.
An accountant and a client at the year-end meeting

What is still uncertain

CP26/10 closed on 22 May 2026 and no policy statement has followed. The “sufficient information” standard, the single attitude-to-risk concept and the move from annual to periodic suitability reviews are proposals and may change in the final rules. The FCA has not given a date for its policy statement, and until it does no firm can build a simplified advice service to a fixed specification. The FCA's advice guidance boundary review page and CP26/10 itself are the sources to follow.

The Vanguard figure measures appetite at one point in time among the audience of one asset manager's roadshow. It was reported by two trade titles on the same day. It is not a count of services that exist or a forecast of when they will.

Why the change is happening

The FCA's Financial Lives 2024 survey found that 8.6% of UK adults had taken regulated financial advice in the previous twelve months, and 13% of the self-employed. The lang cat's State of Advice Report 2025 counted fewer than 5,000 IFA firms, an average new client portfolio of £411,000 and an average client age of 59. The advice gap sets out the size of the shortfall.

Narrower services would bring regulated advice to people who have never had it. More clients would be advised, each on a smaller set of facts. For a business owner, the facts outside that smaller set are in the accountant's files.

Common questions

What is simplified advice, and is it available now?

Simplified advice is regulated financial advice given over a narrower set of facts than a full planning engagement. It is not yet available. The FCA consulted on it in CP26/10, Simplifying the pensions and investment advice rules, which opened on 25 March 2026 and closed on 22 May 2026. The FCA has said it will publish feedback and a policy statement once it has reviewed responses. As at 7 September 2026 no policy statement has been published and no implementation date has been given.

How is simplified advice different from targeted support?

Targeted support has been in force since 6 April 2026 and is not advice. A firm identifies a group of consumers with common characteristics and makes a suggestion to that group, without assessing whether it suits any one person. Simplified advice, as proposed in CP26/10, would be advice. It would produce a personal recommendation with a suitability assessment behind it, over a narrower set of facts than a full engagement collects.

Is “sufficient information” a weaker standard than “necessary information”?

It is a different test, and the duty stays with the adviser either way. The current rule requires a firm to obtain the information necessary to assess suitability. CP26/10 proposes an expectation that advisers consider sufficient information. Sufficiency is judged against the scope of the service, so a narrow service can be advised on a narrower set of facts. Scope therefore carries more weight, and the client may not know what their own scope left out.

What would a narrower fact-find not ask a business owner about?

The company. A personal fact-find asks about income, existing pensions and investments, timescale and attitude to risk. It does not ask what the company holds in its account, how much of that is committed to the next VAT return and the corporation tax due in nine months, whether the director's loan account is in credit or overdrawn, whether the company could make an employer pension contribution in place of a personal one, or whether a sale is under discussion. Each of those can change the answer, and each is in the accountant's files.

Does an accountant need any permission to raise this with a client?

No. Noticing a fact and asking a question are not regulated activities. An accountant without FCA permissions cannot recommend a product, a provider or a course of action, and should not comment on whether advice a client has received was right for them. An accountant can ask what the advice covered, record the answer, and with the client's agreement pass the company-side facts to the adviser before a recommendation is finalised. The client's agreement is needed because passing their financial information to a third party without it is a data protection matter.

Does a narrower engagement leave the client with fewer protections?

The proposals in CP26/10 are about the suitability rules. A personal recommendation from an authorised firm remains a personal recommendation, with the complaints and compensation routes that attach to it. What changes is how much of the client's position the firm was required to look at before making it. The client keeps their recourse. The risk is that a sound recommendation on the question asked is the wrong move overall, because a material fact was never in scope.

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