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April 2026 – Retirement Income Advice – Are Firms Where They Need to Be?

Consistency, structure and evidencing suitability in a changing regulatory environment

Retirement income advice is starting to come back into focus from the FCA, which is perhaps to be expected given the increasing number of clients moving into decumulation and the complexity that comes with it. Unlike accumulation, this stage of advice involves a greater degree of judgement, with considerations such as income sustainability, sequencing risk and changing client circumstances all playing a role.

From our experience working with firms, the challenge in this area is rarely technical knowledge. Most advisers understand the key risks and how to manage them. Where issues tend to arise is in the consistency of approach.

It is not uncommon to see variations between advisers, even within the same firm. Income decisions may be reached in slightly different ways, the rationale behind them is not always clearly documented, and the depth or structure of ongoing reviews can vary. These differences do not always present a problem in day-to-day advice, but they become much more visible when viewed through a regulatory lens.

The FCA’s focus is increasingly on how advice outcomes are reached, rather than simply whether they appear reasonable. Firms are expected to demonstrate a clear and repeatable approach, supported by evidence that decisions have been made consistently and in line with client needs.

In practice, this is often where gaps begin to appear. Without a defined framework, it can be difficult to show that similar clients are being treated in a similar way, or that income strategies have been arrived at using a consistent methodology. Over time, these small inconsistencies can build into a position that is harder to justify under scrutiny.

For many firms, introducing a more structured approach, often through a Centralised Retirement Proposition, helps to address this. Not as a compliance exercise, but as a way of bringing clarity and consistency to what is naturally a more judgement-based area of advice. It also makes it significantly easier to evidence suitability and demonstrate that good outcomes are being delivered.

In our experience, this is not about starting from scratch, but about sense-checking and strengthening what is already in place. We often work with firms to review how retirement income advice is being delivered in practice, looking at consistency between advisers, how income decisions are reached and documented, and how robust ongoing reviews are over time. Where needed, this can include supporting the development or refinement of a Centralised Retirement Proposition, helping to bring more structure to the process without losing the flexibility advisers need.

The aim is straightforward – to ensure that the approach stands up just as well under scrutiny as it does in practice.

The question for firms is a straightforward one. If retirement income advice were reviewed today, would it reflect a clearly defined and consistently applied approach, or a series of individual decisions? In our experience, that is where taking a step back and reviewing the framework can be particularly valuable.

If you’re unsure how your current approach would stand up under FCA scrutiny, it’s a good time to take a closer look. We’re happy to help.

Complete Compliance Support Limited

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