A&O Shearman | FinReg | UK lays SI to create new regulated activity of providing targeted support
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  • UK lays SI to create new regulated activity of providing targeted support

    30 January 2026
    The Financial Services and Markets Act 2000 (Regulated Activities) (Providing Targeted Support) (Amendment) Order 2026 was laid before UK Parliament and published with an explanatory memorandum. The instrument, following the draft version published in July 2025, amends the Financial Services and Markets Act 2000 (Regulated Activities) Order 2001 (RAO) to introduce a new specified activity of "providing targeted support". This will enable firms to make recommendations that are designed for groups of consumers with similar characteristics and circumstances. Targeted support will be expressly distinguished from the existing regulated activity of "advising on investments" under Article 53. The UK Financial Conduct Authority (FCA) has said, "These once-in-a-generation reforms will help people navigate their financial lives and give them greater confidence to invest. This is a win-win for consumers and firms alike."

    Firms wishing to provide targeted support will require a new authorisation from the FCA or, where relevant, the UK Prudential Regulation Authority (PRA). The FCA is developing bespoke conduct rules distinct from the requirements that apply to firms which carry on the activity of advising on investments. The near-final rules were published in December 2025, and (among other things) will enable firms to provide targeted support to customers without charge, whereas investment advice must generally be charged for. The Order also makes consequential amendments to the RAO to ensure continued alignment across primary and secondary legislation and includes staged commencement to allow the regulators to make rules and assess applications for permission in advance of the regime coming fully into force on 6 April. The FCA currently says that the application gateway will open in March.

    The government intends to introduce further legislative changes related to targeted support later in the year, to ensure the regime operates effectively. These will be technical changes to ensure alignment between the regulation of targeted support and advising on investments in relevant secondary legislation. These changes do not include adding the provision of targeted support to the list of permitted business of appointed representatives in Regulation 2 of the Financial Services and Markets Act 2000 (Appointed Representatives) Regulations 2001.

    For further background on targeted support, you may like to read our following publications: our snapshot on the FCA's new targeted support regime; our summary information; our FAQs; and our information on the practicalities of applying for permission to conduct the new regulated activity of providing targeted support.

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