Consumers face complex decisions at critical financial moments. The FCA’s proposed targeted support regime could reshape how firms deliver help, making it easier, safer and more scalable for the mass market to get the support they need. Altus Consulting, part of Accenture, welcomes the FCA’s proposals to introduce a targeted support regime and commends the ambition to close the persistent advice gap in pensions and retail investments. We agree that the regime should be judged not by its inputs, but by its ability to deliver better outcomes – defined not solely by consumer action, but by improvements in understanding, confidence, and decision readiness.
This executive summary explains where Altus Consulting, part of Accenture, aligns with the FCA, where we recommend stronger clarity, and how to make the regime work in practice for pensions, annuities and consolidation decisions.
Key areas of alignment
- Purpose Framing: we support for the FCA’s use of ‘better outcomes’ as the regimes purpose statement. This framing is consistent with the language of the Consumer Duty and reflects the FCA’s broader shift toward outcomes-based regulation.
- Segment-Level Suitability and Communications: we endorse the proposal to judge suitability at the segment level, using reasonable assumptions and proportionate evidence. We also support the FCA’s shift toward flexible, outcomes-focused communications.
- Flexibility and Iterative Implementation: we welcome the FCA’s intention to build the regime on existing regulatory foundations, including Consumer Duty and PROD, and to avoid unnecessary duplication of rules. Just as importantly, we support the principles-based design of the regime, which enables innovation, accommodates evolving delivery models, and allows firms to test and refine their approaches over time.
Areas where we propose enhancements
- Clarify the relationship to Consumer Duty and Provide Regulatory Reassurance: while the regime is clearly aligned to the Consumer Duty, we believe that it remains unclear whether targeted support is intended to help firms meet their Duty obligations or whether it constitutes a distinct regime with separate expectations. We also believe that regulatory reassurance is essential to ensure confidence in the regime’s evidentiary standards.
- Expand Scope Beyond Personal Recommendations: We are not in favour of the proposal to limit targeted support to personal recommendations. We believe this framing risks narrowing the regime’s perceived purpose and excluding valuable forms of support that fall short of a recommendation but still improve consumer outcomes.
- Reconsider Restrictions on Annuities and Consolidation: We are not in favour of the proposed ban on suggesting a particular annuity. This restriction contradicts the regime’s premise that targeted support may include personal recommendations and risks undermining support at a critical financial juncture.
- Support for Trustees and Hybrid Journeys: We believe many pension scheme trustees will want to provide services to their members that are akin to targeted support, particularly in relation to decumulation decisions. However, trustees may be unsure how far they can go without triggering regulated activity.
“Targeted support represents a significant opportunity to reshape how financial services engage with the mass market. By enabling structured, proportionate interventions that improve decision readiness without requiring full advice journeys, the regime can help consumers navigate complex financial choices with greater confidence. It offers a scalable way to make financial services more accessible, relevant, and useful – particularly for those who have historically been underserved by traditional advice models.”
Download the executive summary (PDF)
