A&O Shearman | FinReg | HMT consultation response on new targeted support for pensions and retail investments
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  • HMT consultation response on new targeted support for pensions and retail investments

    11 December 2025
    HM Treasury has published its consultation response on introducing a new "targeted support" regime following the advice guidance boundary review. The regime will allow authorised firms to provide tailored investment and pension recommendations to groups of consumers with similar characteristics. The government confirmed that targeted support will be established as a distinct regulated activity under the Financial Services and Markets Act 2000 (Regulated Activities) Order 2001 subject to bespoke conduct standards and authorisation from the UK Prudential Regulatory Authority and UK Financial Conduct Authority (FCA).

    Key changes following feedback to the draft statutory instrument and policy note include: simplified disclosure requirements aligned with FCA rules; clarification of exemptions applicable to targeted support; decision to proceed with secondary legislation enabling workplace pension providers to deliver targeted support communications under the Privacy and Electronic Communications (EC Directive) Regulations 2003 and other technical adjustments. Appointed representatives will initially be excluded from delivering targeted support, with a review planned after reforms to their regime are implemented.

    HM Treasury intends to lay the necessary statutory instrument as soon as Parliamentary time allows. Rollout for the activity is planned for April 2026, with the gateway for applications opening in March 2026. The FCA has also opened their pre-application support service for firms planning to apply for targeted support permissions. Separately, the FCA published its final rules following its June consultation for targeted support. The FCA has also published two separate joint statements with the Information Commissioner's Office and UK Financial Ombudsman Service.

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