Last Updated on September 21, 2026
Since 6 April 2026, a pension provider can send a group of its customers a suggestion about what to do with their money, and the FCA does not count it as advice. Most advice firm websites still read as though that change never happened.
This guide sets out what targeted support is, what the rules actually say, and the three sentences an advice firm should check on its own site this week.
A note before we start. Whito is not authorised or regulated by the Financial Conduct Authority and has no firm reference number. This page is marketing guidance for advice firms. It is not financial advice, compliance advice or a financial promotion for any firm. Every rule quoted below was read at source on 21 September 2026. Check anything you publish against the FCA Handbook and with your own compliance support. Corrections: hello@whito.co.uk.
What targeted support is, in the FCA’s words
The FCA describes targeted support as a way for firms to provide suggestions designed for groups of consumers with common characteristics, to help them make important decisions about pensions and investments. It sits between free guidance, which stays unregulated, and full advice, which considers one person’s whole situation.
The FCA’s stated reason is scale. It says around 23 million consumers are currently underserved by the markets for advice and guidance.
In practice a firm defines a consumer segment, writes a ready-made suggestion that it has a reasonable basis to believe suits everyone in that segment, checks that a customer fits the segment, and then delivers the suggestion. The customer is told it is not a personal recommendation.
The facts that matter to an advice firm
All read on 21 September 2026. Rule references are from the FCA instrument that created the regime, FCA 2026/5.
| Fact | What it says | Source |
|---|---|---|
| Live date | Final rules confirmed 26 February 2026. Applications for the permission opened 2 March 2026. The regime went live on 6 April 2026. | FCA PS25/22 |
| A separate permission | Targeted support is its own regulated activity. A firm needs the specific permission, applied for through FCA Connect. | FCA, 2 March 2026 |
| Appointed representatives | “Providing targeted support is not permitted business of appointed representatives.” | COBS 9B.2.4G |
| Safeguarded benefits | “A firm must not provide targeted support in relation to safeguarded benefits.” Defined benefit pensions stay with advisers. | COBS 9B.2.3R |
| Consolidation | A ready-made suggestion must not include an express or implied recommendation to consolidate pensions. | COBS 9B.4.38R |
| What the customer is told | That the suggestion is not based on a comprehensive consideration of their circumstances, is not specific to them, and which characteristics of the group it was built on. | COBS 9B.6.3R and 9B.6.5R |
| Compensation | The FSCS may pay compensation for unsuitable targeted support given from 6 April 2026, up to £85,000 per eligible person, per firm. | FSCS |
| Complaints | The FCA and the Financial Ombudsman published a joint statement on 11 December 2025. The Ombudsman says complaints that reach it will be considered with careful attention to the FCA’s rules for the regime. | Financial Ombudsman |
| Who holds it so far | Seven firms authorised and 13 applications made, according to an FCA Freedom of Information response reported on 1 July 2026. All seven were pension, investment or banking providers. | Professional Adviser, 1 July 2026 |
Two rows in that table decide most of what follows. Appointed representatives cannot offer it. And the work that carries the most risk, safeguarded benefits and consolidation, is kept out of it.
The mistake most advice firms are making
There are two, and they point in opposite directions.
The first is silence. A firm’s site describes advice the way it did in 2023, as though the only alternative to paying an adviser is doing nothing. A prospect who has just received a suggestion from their pension provider reads that and wonders why the firm does not seem to know.
The second is borrowing the language. “Targeted financial support”, “tailored guidance”, “quick suggestions”. Targeted support is now a regulated activity with its own permission. Describing a service in terms that sound like it, when the firm does not hold the permission, sits badly with COBS 4.2.1R, which requires every communication to be fair, clear and not misleading.
The principle is simple. Say what you are, in the words the regulator now uses, and say where your service starts.
Start: check three sentences on your own site
This costs nothing and takes an afternoon.
- Your service description. Search your site for “support”, “guidance” and “suggestion”. If any of them describes something you offer, make sure it cannot be read as targeted support unless you hold that permission.
- Your status line. If you are an appointed representative, name your principal. It matters more now, because the regime itself treats ARs differently. Our guide to the sentence most adviser websites get wrong has the wording.
- Where advice starts. One plain paragraph saying what full advice considers that a group suggestion cannot: the whole of someone’s circumstances, and the areas targeted support is barred from.
Build: a page that explains the three routes
Prospects now arrive having met more than one kind of help. A single page that lays out the routes honestly will be read, and it is the kind of page AI assistants quote when asked the difference.
| Route | Regulated? | Considers your whole situation? | Typical provider |
|---|---|---|---|
| Guidance | No | No | Free government services and providers’ own information |
| Targeted support | Yes, with its own permission | No. Built for a group you fit | Pension, investment and banking providers holding the permission |
| Full advice | Yes | Yes | An authorised advice firm or its appointed representatives |
Keep it factual. Do not describe targeted support as second rate. It is regulated, it carries FSCS protection, and complaints about it go to the Financial Ombudsman. The honest point is that it answers a group’s question, not the client’s.
Then publish what your advice costs, in pounds, with one worked example. A prospect comparing a free suggestion with a paid recommendation needs the price to make the comparison. Our guide to what advice costs, and what a lead costs sets out the published benchmarks.
Scale: the client who has outgrown a suggestion
Once the foundations are in place, the regime opens up a clear piece of positioning.
- Safeguarded benefits. Targeted support cannot touch defined benefit pensions. If you hold the pension transfer permission, that is work only you can do, and it deserves its own page.
- Consolidation. A ready-made suggestion cannot recommend consolidating pensions. People with several old pots are exactly the ones likely to go looking for someone who can.
- Complexity. Business owners, divorce, inheritance, at-retirement income. A segment cannot hold these. Name them as specialisms, narrowly.
Write these as pages that answer a question a person would ask. “My pension provider sent me a suggestion. Should I get advice?” is a query that did not exist before April.
What we do not know yet
Whether targeted support takes clients away from advice firms, sends them new ones, or does neither. Nobody has published data on it, and we will not guess. The FCA’s own projection, reported alongside the FOI figures, was that around 96 firms would eventually offer it. Seven held the permission by the start of July.
What we can measure is how advice firms appear when someone asks an AI assistant for a financial adviser. We have already done it for mortgage advisers: of 88 firms named by two engines across 12 cities on 8 September 2026, 50 were appointed representatives trading under a name that is not the authorised firm. The full register check is free to read. The same check on advice firms is next, and it will land on the financial advisers hub first.
Common questions
What is targeted support?
A regulated service, live since 6 April 2026, in which a firm with the permission gives a ready-made suggestion to a group of consumers who share common characteristics. It covers pensions and investments. It is not a personal recommendation, and the customer must be told so.
Can an appointed representative offer targeted support?
No. COBS 9B.2.4G says providing targeted support is not permitted business of appointed representatives.
Can targeted support be used for a defined benefit transfer?
No. COBS 9B.2.3R says a firm must not provide targeted support in relation to safeguarded benefits, and a ready-made suggestion must not recommend consolidating pensions (COBS 9B.4.38R).
Is targeted support covered by the FSCS?
The FSCS says it may pay compensation if someone received unsuitable targeted support from 6 April 2026 and lost money, up to £85,000 per eligible person, per firm, where the firm was FCA regulated at the time.
Should an advice firm apply for the permission?
That is a business decision for the firm and its compliance support, not a marketing one. What every firm should do is describe its own service accurately, whichever way it decides.
The takeaway. Since April, a vague description of advice costs a firm more than it used to. Say what you are, say where full advice starts, and publish what it costs.
See what search engines and AI assistants can read on your own site with the free Visibility Check: seventeen checks, about twenty seconds, no email. Then list your firm free in the Whito directory. Money cannot buy either.