Anisha Kalam breaks down the FCA’s consultation on Targeted Support, highlighting the key Handbook updates, compliance considerations, and next steps for firms preparing to integrate this new framework.
The FCA has published Consultation Paper CP25/26, setting out the consequential changes to the FCA Handbook required to implement its proposed framework for Targeted Support which was first introduced in CP25/17.
CP25/26 has been introduced to focus on the detailed changes needed across the FCA Handbook to operationalise this framework. The goal is to enable firms to offer tailored, non-personalised support to groups of consumers with shared characteristics. This latest paper outlines the technical amendments needed to embed Targeted Support into existing regulatory structures, enabling firms to offer structured, non-personalised guidance to groups of consumers with shared characteristics.
The consultation is open until 17 October 2025, with final rules expected in December 2025. The authorisations gateway for firms seeking permission to provide Targeted Support is scheduled to open in March 2026.
Why Targeted Support?
The FCA has identified the advice gap as a key source of consumer harm. Millions of people are unable to access financial advice, often due to cost, eligibility, or lack of awareness. This means leaving them without support on pensions, investments, and financial planning.
Targeted Support aims to bridge this gap. It will not be a personal recommendation, but will go beyond generic guidance. It will allow firms to deliver structured interventions that help consumers make better informed decisions, while still operating within regulatory boundaries.
Who Will Be Affected?
The proposals in CP25/26 have cross-sector implications. The FCA highlights the following groups as being particularly impacted:
- Firms subject to COBS 19
- Pensions and investment firms, including platforms, wealth managers, and SIPP operators
- Pension trustees and trust-based schemes
- Banks, building societies, mutuals, and friendly societies
- Financial advice firms
- Trade bodies, consultants, and consumer representatives
This broad scope reflects the FCA’s intention for Targeted Support to extend beyond traditional advice models.
Fundamental Handbook Changes – What you need to know
To support the rollout of Targeted Support, the FCA is proposing a series of detailed updates across multiple sections of the Handbook. These amendments are designed to ensure the new framework is fully integrated into existing regulatory structures.
Glossary
- Adds references to Targeted Support in definitions such as distribute, lifetime ISA charges, and marketing
- Clarifies that Investor Compensation Directive (ICD) claims do not apply
- Excludes Targeted Support from the definition of corporate finance business
SYSC and SMCR
- SYSC 5: Extends employee competence requirements
- SYSC 25: Requires responsibilities maps and handover procedures to include Targeted Support
- SYSC 19G: Clarifies remuneration rules and the classification of staff as material risk takers
COBS
- COBS 1: Applies structured deposit rules
- COBS 2.3 & 2.3A: Requires inducement disclosures
- COBS 6.1B–F: Prohibits commissions and restricts inducements
- COBS 7: Applies demands and needs assessments for life policies
- COBS 10: Disapplies appropriateness tests
- COBS 14: Extends product disclosure requirements
- COBS 15: Applies cancellation rights
- COBS 16.6: Requires pension statements to signpost Targeted Support
- COBS 19: Aligns with Pension Wise and investment pathways
Insurance and Dashboards
- ICOBS: Clarifies conduct rules for insurance contracts involving Targeted Support
- PDCOB 12: Prevents pension dashboards from misrepresenting post-view services as Targeted Support
Supervision and Complaints
- SUP 16: Updates reporting requirements (e.g. PSD002, REP015/016)
- DISP 1: Adds Targeted Support to complaints reporting categories
COLL, FUND, and CREDS
- AIFMs and UCITS ManCos: Permitted to offer Targeted Support under “investment advice”
- Credit Unions: Prohibited from offering Targeted Support on complex instruments like deferred shares
What Firms Should Do Now
CP25/26 is more than a technical update, it introduces a new regulated activity that firms must integrate across governance, compliance, and client processes.
Key actions for firms:
- Governance & SMCR: Map Targeted Support into responsibilities frameworks and senior manager oversight
- Training & Competence: Ensure staff meet SYSC 5 standards
- Consumer Communications: Update pension statements, disclosures, and cancellation rights
- Remuneration: Remove commission structures and disclose any cross-subsidisation
- Systems & Reporting: Update regulatory returns to reflect Targeted Support
- Complaints Handling: Ensure DISP categorisations reflect Targeted Support accurately
Firms intending to offer Targeted Support should begin preparations now, ahead of March 2026.
How Thistle Initiatives Can Help
At Thistle Initiatives, we specialise in helping firms navigate complex regulatory change. With CP25/26, the challenge lies in implementation and integration, embedding Targeted Support into governance, reporting, and consumer-facing processes without introducing regulatory risk.
Whether you're assessing your readiness or preparing for authorisation, our team is here to support you every step of the way. If you’d like to speak to one of our regulatory specialists about how these changes may affect your business, please get in touch.
Meet the Expert
Anisha Kalam, Senior Consultant 
Anisha is a compliance specialist with over six years of experience in financial services, specialising in FCA regulations and OFSI sanctions. She has successfully implemented global compliance programs, introduced cost-saving monitoring systems, and ensured adherence to regulatory requirements.
Anisha's expertise spans sanctions analysis, regulatory risk mitigation, policy drafting, and compliance audits. With a proven track record in reducing compliance risks and managing high-stakes regulatory projects, she brings technical precision and leadership to every role.