Finally, changes to annual suitability reviews?

If the FCA’s proposed amendments to suitability reviews moves away from a hard ‘annual suitability review’ rule, the firms that win will be those that treat it as a chance to redesign their whole advice and review model, not just tweak a process.

At Fractyl Consulting, we’re already helping advice, wealth and platform businesses think about what ‘next‑generation’ ongoing suitability looks like in practice.

We see three big shifts:

From calendar‑driven to risk‑driven:  

• Moving from a blunt, genuinely despised annual tick‑box to a risk‑based, event‑triggered approach – so that vulnerable, complex and higher‑risk clients still get frequent, proactive reviews, while low‑risk segments move to a more proportionate cycle.

From an equally despised ‘annual review pack” to smarter journeys:  

• Slimming down repeat reports, focusing on what has actually changed in the client’s life, objectives and portfolio, and using digital pre‑questionnaires and MI to target adviser and client time, where it adds actual value.

From rule compliance to outcome evidence:  

• Re‑framing governance, Management Information and SMCR ownership around Consumer Duty outcomes, fair value and ongoing‑service delivery - proving that a lighter touch is still delivering good client results and not sliding into "fee for no service”.

This is where Fractyl Consulting lives - at the intersection of regulatory interpretation, operating‑model design and practical change delivery.

We help firms:

• Redesign their suitability and ongoing‑service framework (segmentation, triggers, MI, and controls).  

• Re‑platform processes and workflows so operations, advisers, compliance and internal audit are aligned.  

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  Translate the new regime into clear client communications, revised Terms of Business and sustainable adviser behaviours.

If your firm is starting to ask 'What replaces the annual review for us - and how do we explain it to clients, external auditors and the FCA?’, we’d be happy to share what we’re seeing across the market and explore how we can help.

Message us directly or visit www.fractylconsulting.com to start the conversation.