FCA targeted support, from the customer outcome.
Targeted support is the FCA's framework for suggestions on pensions and retail investments. A firm can give a ready-made suggestion to people who share a financial need, using limited information, rather than a full review of one person's circumstances. The policy statement is PS25/22. The rules are in COBS 9B. This note is about what that means for the customer in a wealth or pensions firm. Your compliance lead owns the regulatory interpretation.
What the FCA has put in place
PS25/22 was first published on 11 December 2025, as near-final rules. The page was updated on 27 February 2026 to record that the FCA Board made the final rules on 26 February 2026. The FCA says the changes since the near-final text were mostly cross-references to the legislation that creates the new activity, plus one minor policy change explained in the Handbook Notice. Firms could apply for permission from 2 March 2026. The regime went live on 6 April 2026. The Handbook page for COBS 9B shows a last update of 6 April 2026.
The FCA says the framework is for pensions and investment firms, including fund and wealth managers, platforms and SIPP operators, and for pension trustees and trust-based schemes, among other firms. On the same page it estimates that around 23 million consumers are underserved by the markets for advice and guidance. That figure is the FCA's estimate, not one I have produced.
COBS 9B.1 says the purpose is to enable firms to support clients on decisions about investments and pensions, at scale, on the basis of limited information rather than a comprehensive view of a client's characteristics or circumstances. The support is for a shared financial need or objective. It is delivered as a ready-made suggestion, by reference to a pre-defined consumer segment. It is designed to put the client in a better position than if they had not received the service.
The same chapter says the cross-cutting obligations under the Consumer Duty do not require a firm to provide targeted support. Offering it is a choice. Once a firm offers it, the design and delivery rules apply. The longer note on the Duty as I work with it is on the Consumer Duty page.
The design test is a customer outcome
COBS 9B.1 says a firm should design the service only where it has reasonable grounds to consider that the people it is designed for would be in a better position than if the support were not provided. A ready-made suggestion developed for that purpose has to be suitable for an individual in the consumer segment. The chapter points to COBS 9B.4.20R for that requirement.
COBS 9B.3 says this service is not subject to the suitability requirements in COBS 9 or COBS 9A. Principle 9 still applies: a firm must take reasonable care to ensure the suitability of its advice for any customer who is entitled to rely on its judgement. For the targeted support service itself, the firm must treat the client as a retail client, even if that person is categorised differently for other business.
The design question for a wealth or pensions firm is whether you can show that this group is better off with the suggestion than without it. The segment has to be defined tightly enough for that to be true of the people in it. A suggestion written for a wide group, with a thin shared need, fails that test before anyone argues about the product.
What the customer is told
COBS 9B requires the firm to act with due skill, care and diligence when it communicates with clients, including on the nature and limitations of the service, and to act in a way that is consistent with the duty of good faith towards retail customers. Someone receiving a ready-made suggestion has not had every part of their circumstances reviewed. The journey needs to say that in words the customer can use.
The chapter also covers support that follows some of the same method but is not a targeted support service, for example because the suggestion is not a recommendation in relation to a particular investment. In that case the firm should still make sure the consumer understands the nature of the support they are receiving.
Watching the outcome after the suggestion
COBS 9B.10 points firms back to the duty to monitor retail customer outcomes in PRIN 2A.9. For targeted support, the Handbook says firms should use that monitoring to identify whether the service is consistent with good outcomes, including whether ready-made suggestions could lead to harm because of:
- how the firm designed its consumer segments
- how it specified the ready-made suggestions
- how it aligns clients with those segments
- a suggestion that is no longer suitable for individuals in the segment
The same section asks firms to understand whether clients in particular situations, or with particular characteristics, are routinely unable to be aligned with a segment. That is a prompt to consider a new segment, not a reason to leave those people with a suggestion that does not fit. It also asks firms to consider whether a product used in a suggestion still fits the segment, including where the manufacturer has made a significant change to the product.
COBS 9B.10 says this monitoring does not require an ongoing suitability assessment of the kind in COBS 9 and COBS 9A, unless the firm's service to the client already includes a periodic assessment of suitability. PRIN 2A.9 still requires monitoring that can show whether any group of retail customers is getting a different outcome from another group of customers of the same product, and whether any retail customer has suffered harm from the firm's acts or omissions.
Limits that matter in pensions
COBS 9B says a firm must not provide targeted support in relation to safeguarded benefits. Providing targeted support is not permitted business of appointed representatives.
On pension consolidation, the Handbook's guidance on COBS 9B.4.38R says a firm must not give information or support on consolidation that is so closely connected to the targeted support service that it amounts to an express or implied recommendation to consolidate pots. A firm can still provide targeted support where a client has several pension pots, if the decision does not rely on those pots being combined. The Handbook gives options at retirement as an example.
The chapter says FG21/1, the FCA's guidance on the fair treatment of vulnerable customers, is relevant to design and delivery of targeted support. It also points firms to the Equality Act 2010, or the equivalent legislation in Northern Ireland, and to the Duty's requirement to monitor whether any group of retail customers is experiencing different outcomes and to act where they are. How I work on that part of a journey is on the vulnerable customers page.
What I would change in a wealth or pensions journey
Write the shared need in one sentence before the suggestion is designed. If that sentence only works by ignoring large differences inside the group, the segment is not ready.
In the journey, say what the support looks at and what it leaves out. Keep a route for the person who does not fit the segment. That includes a customer in vulnerable circumstances, which FG21/1 already brings into the design. Then use the monitoring COBS 9B.10 describes: segments, the suggestion itself, the matching process, suggestions that have stopped fitting, and the people who cannot be matched.
I do this as a change to the journey with the team that owns it. I do not replace your compliance function.
Common questions
When did FCA targeted support go live?
PS25/22 was published on 11 December 2025. The FCA Board confirmed the rules on 26 February 2026. Firms could apply for permission from 2 March 2026. The FCA says the regime went live on 6 April 2026. The Handbook chapter COBS 9B shows an update date of 6 April 2026.
Is targeted support the same as full advice?
No. COBS 9B describes support at scale, on limited information, through a ready-made suggestion for a pre-defined consumer segment. The chapter says the service is not subject to the suitability requirements in COBS 9 or COBS 9A. Principle 9 still applies, and the firm must treat the client as a retail client for that service. The customer needs to be told what the support is and what it does not cover.
What should a wealth or pensions firm monitor after a suggestion is given?
COBS 9B.10 points firms to the Consumer Duty monitoring duty in PRIN 2A.9. For targeted support, the Handbook says firms should look for harm from the design of segments, the specification of ready-made suggestions, the way clients are matched to a segment, and suggestions that are no longer suitable. It also asks firms to notice clients who cannot be aligned to a segment, and to check that a product in a suggestion still fits if the manufacturer changes it. That monitoring does not by itself require an ongoing suitability assessment, unless the service already includes one.
Sources
- FCA, PS25/22: Supporting consumers' pensions and investment decisions: rules for targeted support. First published 11 December 2025. Updated 27 February 2026.
- FCA Handbook, COBS 9B Targeted support. Page viewed showing a last update of 6 April 2026.
- FCA Handbook, COBS 9B.10 Systems and controls, including ongoing monitoring.
- FCA Handbook, PRIN 2A.9 Monitoring of consumer outcomes.
- FCA, FG21/1: Guidance for firms on the fair treatment of vulnerable customers, as cited in COBS 9B.