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Financial advice

Keep oversight of your advice network on record

For advice networks and wealth firms whose ARs are adviser practices, from sole traders to multi-adviser firms.

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Thousands of practices under a few hundred principals

A small number of networks oversee a large share of UK advice. Each AR is a business in its own right, with its own clients, fees and liabilities that the principal answers for.

ARs under 340 advice principals (April 2026)
6,610
financial advisers in the UK
31,000
networks with investment and pensions permissions (January 2025)
147

The rules that matter in this sector

One principal only
An AR doing retail investment business may have only one principal for it (SUP 12.5.6AR).
Ongoing fees need an ongoing service
Ongoing adviser charges are allowed only for an ongoing service the client can cancel, and charges must be disclosed in cash terms (COBS 6.1A).
Pension transfers
Advice must be given or checked by a pension transfer specialist, starting from the assumption that a transfer is not suitable, and contingent charging is banned (COBS 19.1).
Every adviser needs a current SPS
Training and competence applies to AR advisers. Each needs an annual Statement of Professional Standing from an accredited body and at least 35 hours of CPD a year (TC 2.1).
No targeted support through ARs
The government decided ARs may not deliver targeted support at its launch on 6 April 2026, and will review that once the AR reforms are established.

What the FCA has said recently

  1. March 2026

    Consumer investments regulatory priorities

    The FCA expects firms to oversee ARs effectively, and has seen firms with minimal regulated activity use FCA permissions to appear credible. It planned follow-up work on ongoing advice in the first half of 2026.

  2. 25 March 2026

    CP26/10 on simplifying advice rules

    The FCA proposed replacing the annual suitability review with periodic reviews based on clients' needs. Final rules were expected in the fourth quarter of 2026.

  3. 24 February 2025

    Ongoing advice services review

    Across 22 large firms, reviews were delivered in about 83% of cases and not attempted in under 2%, where redress is likely due. All firms were asked to check they can evidence delivery back to 2018.

  4. 7 October 2024

    FCA letter to advisers and investment intermediaries

    Principals must make sure their ARs hold adequate financial resources for potential redress, and must not seek to avoid redress liabilities.

Between annual reviews

An adviser’s SPS lapses
Each Individual's certificates and declarations are held on their record, with tasks raised before they are due.
Fit & Proper
A finding without a follow-up
Assign issues to your team and record the investigation, the evidence and the outcome.
Monitoring & issues
Approval decisions hard to trace
Keep the assessor, the decision and the information reviewed together, even after the records change.
Evidence & audit trail

What to collect from each AR

Merrin schedules these as returns, by risk tier, and puts each one with the firm or Individual who needs to provide it.

Returns & tasks
  • Each adviser’s CF30 status, qualifications, SPS issuer and expiry, and CPD hours
  • Clients on ongoing service, and reviews due, delivered and declined
  • Initial and ongoing charges, and fee-stops or refunds
  • Pension transfer and retirement income business, and who checked it
  • Complaints by product and cause, and revenue for REP025
  • Redress provisions, PII cover and exclusions
  • The firm’s financial crime risk assessment and its date
  • Changes of control, acquired client books and other appointments

Where Merrin fits

Merrin sits alongside your advice CRM as the principal’s oversight record for firms and Individuals, from onboarding through to reviews and FCA filings.

Keep your existing systems

Client fact-finds, financial planning, suitability assessments, advice file checks and investment administration stay in your existing processes.

Promotion reviews and conduct modules are planned work. Advice-specific returns need to be confirmed before rollout.

See the roadmap

Consumer credit is our initial focus. Talk to us about the fit for an advice network.

Questions from financial advice principals

  • Are we responsible for complaints about our ARs’ advice?
    Yes, for business you have accepted responsibility for. Section 39 FSMA makes the principal responsible for the AR's acts and omissions in that business, and complaints about it fall to the principal and the Financial Ombudsman (DISP 2.3.3G).
  • What did the FCA find about ongoing advice, and how far back must we look?
    Reviewing 22 large firms, the FCA found reviews were delivered in about 83% of cases, clients did not engage in about 15%, and no attempt was made in under 2%, where redress is likely due. It asked all firms to check they can evidence delivery back to 2018.
  • Do advisers in our ARs need a Statement of Professional Standing?
    Yes. Training and competence applies to AR staff. Firms must get independent verification from an accredited body, normally an SPS lasting at most 12 months, from CISI, CII or Walbrook Institute London. Retail investment advisers need at least 35 hours of CPD a year.
  • Can our ARs give targeted support?
    No. HM Treasury decided appointed representatives would not deliver targeted support at its launch on 6 April 2026, and will review that once the AR reforms are established. A principal can hold the permission and deliver it itself.
  • Is the AR regime about to change?
    HM Treasury consulted in February 2026 on requiring FCA permission to act as a principal (existing principals would be treated as holding it), giving the Financial Ombudsman jurisdiction over ARs where the principal is not responsible, and bringing ARs into SM&CR. The consultation closed on 9 April 2026. As of October 2026 the government is analysing the feedback and no response or timetable has been published.

Sources

Checked against these sources on . This is general information, not legal advice.

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