CP26/10: what it means for your annual review process
The FCA published CP26/10 in March 2026. It proposes replacing the mandatory annual suitability review with periodic, needs-based reviews under Consumer Duty. This is the most significant change to the ongoing service obligation since RDR.
What CP26/10 proposes
The consultation proposes that firms move away from calendar-driven annual reviews and instead deliver reviews when there is a genuine trigger: a material change in the client's circumstances, objectives, or risk profile.
For firms currently delivering annual reviews to every ongoing service client, the question is not whether reviews disappear. The question is whether your firm can evidence a structured, needs-based approach to every client segment, not just the top tier.
What stays the same
Whatever the outcome of the consultation, three things remain constant:
Your firm still needs to evidence ongoing value delivery to every client paying an ongoing fee. Consumer Duty still applies. The FCA will still supervise how firms service their lower-fee client segments.
The firms that are exposed are those with large books of ongoing service clients who are not receiving any structured contact at all.
What this means for capacity
If your firm moves to periodic reviews, the review cycle becomes less predictable. Some clients will need reviews more frequently, others less. But the total volume of structured client contact does not disappear. It redistributes.
The firms best positioned are those with scalable review infrastructure that can flex with demand, not those relying on senior advisers to deliver every review manually.
How Pillar fits
Pillar delivers structured annual client reviews for the segments of your book where adviser-delivered reviews do not make economic sense. Under CP26/10, that same infrastructure adapts to periodic, trigger-based reviews.
Whether your firm stays with annual reviews or moves to periodic, Pillar provides the operational capacity and compliance documentation your lower-value client segments need.
Score your firm against CP26/10’s likely requirements.
Or talk to us about how your firm would be affected.