Is this the end of the annual review as we know it?

These developments shouldn’t be seen as a one-off compliance exercise to check if clients are getting what they pay for. Instead, you should treat this as an opportunity to examine whether your service processes actually work. Providing a service at a fair price is a continuous obligation, but if you have good processes already in place, there is little to worry about.

Value comes from continuity of service

We know that Consumer Duty has raised the bar on evidencing fair value across the advice journey, which demands repeated assessments and evidencing client outcomes. The FCA’s CP26/10 makes this explicit. The paper proposes to replace the requirement for annual suitability reviews with periodic reviews based on each client’s needs and circumstances. For many clients, having a need addressed when it arises will be preferable to sticking to a rigid yearly schedule, even when little has changed. Annual reviews might not be disappearing, but their role as the primary touchpoint for ongoing advice seems likely to change.

Many of you will recognise that manual processes and fragmented systems make it difficult to demonstrate that ongoing advice was delivered. However well-intentioned you are, it can be hard to prove delivery of what was promised. This is a result of having to deal with large client books, manual diary systems, disconnected tools and no single source of truth. Adopting technology designed for how advice works today is the practical answer.

The right technology will help you build stronger, more transparent client relationships. Smooth workflows and clean data help you work more efficiently while delivering better long-term outcomes for clients, which is the real measure of fair value.

Technology does much more than help you satisfy a compliance requirement. Advice is heading towards the ‘always-on’ model, which is responsive, continuous and built around client need rather than calendar dates, and the right technology makes it operationally viable.

What good technology makes possible

As the backbone of the entire advice process, your technology should provide capabilities that closely align with your clients’ actual requirements. In practice, that means automated review scheduling so nothing is missed, digital communication tools that create a timestamped record of every interaction and workflow prompts that log completed actions as they happen. Your compliance team gets a clear picture of what has been delivered and when, and the time saved on administration is time available for clients who need more support, or for firms looking to serve a broader range of people.

I believe AI will drive this further. The goal is an advice world where technology flags when a conversation is needed, based on real-time data, so you can act at the right moment. This means contact is driven by what is actually happening in a client’s life, rather than an arbitrary date in the diary.

Technology that centralises all data gives you a full picture of each client’s position while eliminating labour-intensive and error-prone rekeying. Good data doesn’t happen by accident. It’s a product of well-designed systems and consistent processes.

Advice that feels continuous rather than calendar-driven builds client trust more effectively. Not every client finds value in an annual review when little has changed. Interacting with clients at the right moments is a better model for all concerned, and technology makes that possible.

CP26/10 and the FCA’s ongoing advice data request are nudging the industry in a direction it should already be moving. A Policy Statement is expected later this year and while it might not spell the end of the annual review as we know it, it will only strengthen the case for getting your processes and technology in order.

This article was first published in Professional Adviser on 25 September. Please find a link to the original piece here.