What Simplified Advice Changes

Reacting to: Six in ten advisers are considering simplified advice — Money Marketing, 7 September 2026 →

An accountant reading that most of the advice profession is preparing to offer a narrower, cheaper service will reasonably read it as good news, and largely it is. The reason so few clients of a general practice have ever taken regulated advice is not that they were offered it and refused. It is that a full planning engagement costs more than an ordinary situation appears to justify, so it never gets offered at all. A narrower service changes that arithmetic, and it is the most credible answer the profession has produced to a shortfall it has been describing for a decade.

The part that matters for a practice is quieter. A narrower service is narrower because it asks for less, and what an adviser asks for is scoped to the question in front of them. For a salaried client with a workplace pension and an ISA, the personal facts are the whole picture and nothing is lost. For a client who owns a limited company, they are not, because the facts that most often change the answer sit in the company's accounts rather than in the client's own paperwork. Over the next two years more of your clients are going to receive perfectly sound advice on a question that was never quite the question they had.

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 around 200 UK advisers and was carried out as part of Vanguard's Powering your adviser business towards 2030 roadshow. 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 details in the reporting are worth more than the headline number. The first is who is interested: firms focused on long-term growth were the most receptive, and firms preparing for succession or a sale were the least. That is a market sorting itself by time horizon rather than by conviction, and it means the shift will show up unevenly across the advisers your clients happen to meet. The second is the stated catalyst. Professional Adviser, covering the same research the same morning, reported that the coming expansion of inheritance tax to cover unused pensions is driving the interest, particularly around wealth transfer. Advisers are building narrower services because a specific, dated tax change has created a large number of people with one clear question.

It should be read as a statement of intent from about 200 people, not a count of services that exist. Nobody has launched anything yet, for the good reason set out below.

What simplified advice actually is

Simplified advice is not yet a regime. It 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 issue a policy statement once it has reviewed the responses. None has been published as at 7 September 2026, and no implementation date has been set.

The proposals themselves are specific. The FCA is consulting on consolidating the suitability requirements currently split across COBS 9 and COBS 9A into one set of common rules; on replacing the rule requirement to consider “necessary” information with an expectation that advisers consider “sufficient” information when assessing suitability; on clarifying that firms do not always need to assess a customer's knowledge and experience where the product envisaged has a target market that includes clients with no experience; on introducing 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.

This is a different thing from targeted support, which is already live and which we looked at when it launched in targeted support is live. Targeted support has been in force since 6 April 2026 and is not advice at all: a firm identifies a group of people sharing common characteristics and makes a suggestion to the group, without assessing suitability for any individual in it. Simplified advice would still be advice. It would produce a personal recommendation, with a suitability assessment behind it, over a narrower set of facts. The two arrive on separate timetables and answer different questions, and it is worth a practice being able to tell them apart when a client mentions one of them.

Who decides what is enough

The word carrying the weight in all of this is “sufficient”. Under the current rule an adviser must obtain the information necessary to assess suitability. Under the proposal, the adviser must consider sufficient information. In both cases the duty sits squarely with the adviser, and nothing in the consultation moves it onto the client. What changes is the reference point. Sufficiency is judged against the scope of the service being offered, so a narrow service can be properly advised on a narrower set of facts. That is not a loophole. It is the entire purpose of the reform, and it is the mechanism by which advice becomes affordable for people who cannot currently buy it.

The consequence is that scope does more work than it used to. An adviser asks about what falls inside the service. A client answers what they are asked. When a fact that would have changed the recommendation is never mentioned, no one in that room has done anything wrong, because no one in that room knew it was there.

A fact-find is a list of questions. It cannot ask about a fact that nobody in the room knows exists.

Where the missing facts usually sit

What follows is illustrative — a composite built to show the shape of the problem, not a real client and not a comment on any adviser or service.

A client is 61 and the sole director and shareholder of a trading limited company. She takes a salary of £12,570 and around £40,000 in dividends. She has three personal pensions left over from earlier employments, worth roughly £210,000 between them, and she finds the paperwork irritating. The company's bank account shows £340,000. She uses a narrow-scope service to consolidate the three pensions into one, and on the facts that service asks for — her age, the three pots, her income, her timescale, her attitude to risk — the recommendation she receives is a good one.

Here is what her accountant knows and the fact-find had no reason to ask.

• The company could make the pension contribution instead of her. An employer contribution is paid out of company profit, so it reduces the profit charged to corporation tax — 25% on profits over £250,000, 19% on profits up to £50,000, with marginal relief in between, per HMRC's published rates in force since 1 April 2023. Her personal contribution capacity, limited by her £52,570 of relevant earnings, is a materially smaller number than what the company could pay within the £60,000 annual allowance. The route in, not just the destination, is a planning decision.
• The £340,000 is not £340,000. Part of it is the next VAT return and the corporation tax falling due nine months after the year end. The accountant is the only person in the picture who knows which part of that balance is genuinely uncommitted, which is the same problem we set out in the cash question.
• The director's loan account has a balance. Whether it is in credit or overdrawn changes what the cheapest available money is, and in one direction it is not an investment decision at all.
• She has had a conversation with a buyer. A sale under discussion moves her retirement date, and a retirement date is the input on which the whole timescale and risk conversation rests. That interaction is the subject of the joined-up exit.
• Her death benefit nominations are about to matter more. From 6 April 2027 unused pensions fall into the estate for inheritance tax, which is the change driving this entire market shift, and which we covered in when the pension joins the estate.

None of that makes the consolidation advice wrong. Consolidating three small pots may well be the right thing for her to do. The point is narrower and more useful: every one of those five facts would have surfaced in a full engagement, none of them would surface in a narrow one, and all five are already written down in her accountant's files.

What it changes about the year-end conversation

Very little, and that is why it is worth doing. An accountant is not being asked to assess anything, form a view on a recommendation, or acquire a permission. The change is that the sentence “I've sorted my pensions out” will increasingly mean something different from what it meant five years ago, and the difference is invisible unless someone asks about it.

The useful follow-up is one question about scope: what were you asked about? A client can almost always answer that, because they remember the form they filled in. If the answer contains nothing about the company, the accountant now knows something the adviser does not, and the ordinary way that gap gets closed in a joined-up working relationship is the client's own permission to share it. The accountant supplies facts; the adviser, who holds the permissions, decides what they mean and makes the recommendation. That division of labour is described in more detail in the accountant and the adviser, and the consent step is not a formality — passing a client's financial information to a third party without their explicit agreement is a data protection matter as much as a professional one.

Two things worth doing this week

Name the clients whose company changes their personal answer. Not the whole client list. The ones with retained cash above what the business needs, a director's loan account with a real balance, a personal pension contribution the company could be making instead, or a sale conversation that has started. Most practices can list them from memory in twenty minutes, and the list is not a marketing exercise. It is the set of clients for whom a narrow-scope service is most likely to give a sound answer to a narrower question than the one they actually have.

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. Settled once, in a sentence, it removes the standing assumption that all advice looks at the same ground. It costs nothing and it is the only part of this that a practice controls.

What is still uncertain

The substance of the reform is not settled. CP26/10 closed on 22 May 2026 and no policy statement has followed, so the “sufficient information” standard, the single attitude-to-risk concept and the move from annual to periodic suitability reviews are all proposals that could change in the final rules. The FCA has committed to publishing feedback and a policy statement after reviewing responses but has not given a date, and until it does, no firm can build a simplified advice service to a fixed specification. Anyone tracking it should follow the FCA's advice guidance boundary review page and the CP26/10 publication itself rather than trade coverage of adviser intentions.

The Vanguard number carries its own caveat. Around 200 advisers saying they are likely to adapt their models is a measure of appetite at one point in time, taken from the audience of one asset manager's roadshow. It is a real finding, reported by two trade titles on the same day, and it is not a forecast of how many services will exist or when.

Why the shift is happening at all

It helps to keep the scale of the underlying problem in view. The lang cat's State of Advice Report 2025 found that just 9% of UK adults had paid for financial advice in the preceding two years, while 91% of those who did take advice found it valuable. It counted fewer than 5,000 IFA firms in the market, with an average new client portfolio of £411,000 and an average client age of 59. A market built around portfolios of that size and clients of that age was never going to reach most of a general practice's client list by doing more of the same thing, and the shape of that shortfall is set out at greater length on the advice gap.

Narrower services are a serious answer to it. They will bring regulated advice within reach of people who have never had it, and the profession is right to be building them. More clients will be advised, on a smaller set of facts each. For an owner-managed client, the facts that fall outside that smaller set are usually the ones already sitting in the accountant's files.

Common questions