The clearest structural read of UK retail conduct over the past month is not that a new advice product has launched. It is that the FCA has begun to move the boundary between regulated advice and everything else — and is doing it without primary legislation.
Two artefacts mark the shift. The first is the new Targeted Support regime, which went live on 6 April 2026 under PS25/22; firms could apply for permission from 2 March. The second is CP26/10, the FCA consultation on simplifying personalised advice rules, which closed on 22 May 2026. The FCA expects to publish a policy statement by the end of the year.
Treated separately, each is a discrete piece of retail conduct rulemaking. Treated together, they describe a regulator reorganising the bright line that the 2012 Retail Distribution Review made the operative boundary of UK retail conduct for more than a decade. The RDR drew a sharp distinction between regulated advice and unregulated guidance, and most consumer-facing firms have organised their permissions, disclosures and customer journeys around it ever since. The FCA is now reorganising that line through Handbook rules and Consumer Duty — not through an Act of Parliament.
The structural news is the shape of the new landscape. On the FCA’s own Advice Guidance Boundary Review page, the regulator now describes a three-tier model: guidance, targeted support, and personalised advice. Guidance is general information. Targeted support, the new middle tier, allows authorised firms to give suggestions to groups of consumers with shared characteristics. Personalised advice remains an individualised recommendation for a specific consumer’s circumstances.
That ordering is the structural change. The 2012 framework was binary: a consumer was either receiving regulated advice with suitability protections, or general guidance with no firm-side recommendation. The new framework inserts a tier where an authorised firm can say something closer to “people in your position commonly do X” without first performing an individualised assessment.
The FCA’s operative language on what Targeted Support is not is important. In PS25/22 the regulator describes the activity as providing “suggestions designed for groups of consumers with common characteristics” — explicitly group-level rather than bespoke. That is the line that distinguishes it from full advice and that defines the tier’s perimeter.
The motivation is quantitative. The FCA estimates in PS25/22 that “around 23 million consumers are currently underserved by the markets for advice and guidance.” That figure is the FCA’s own estimate, not a measured count, but it is the number that justifies the structural change. The advice gap is presented not as marginal but as the larger share of the UK retail base.
The policy logic follows from that figure. If two-thirds of UK adults sit between guidance that is too generic to be useful and personalised advice that is too expensive to access, the regulator’s choice is either to wait for the cost of advice to fall or to authorise a tier in between. PS25/22 chooses the second.
Targeted Support is only coherent if firms have a positive obligation to design suggestions that actually serve the consumer groups they are aimed at. Without that, the new tier collapses into “guidance with extra steps.” Consumer Duty supplies the obligation.
The FCA frames the relationship plainly on the AGBR page: Targeted Support introduces “a new set of conduct standards, which, alongside the Consumer Duty, provide consumer protections.” Targeted Support is the new permission and the new activity; Consumer Duty is the standing principle that makes the activity defensible. The cross-cutting outcomes under Consumer Duty — products and services, price and value, consumer understanding, consumer support — are what firms must satisfy when they design a group-level suggestion.
This is the part that lets the regime hold together without statute. Parliament has not redrawn the advice perimeter. The FCA has used Handbook rulemaking to insert a new activity, and the existing Consumer Duty principle to give that activity its protective spine.
The consultation that closed on 22 May is the simplifier on the personalised-advice side of the line. CP26/10 proposes consolidating suitability requirements, clarifying when firms must assess customer knowledge and experience, introducing a single attitude-to-risk concept, replacing annual reviews with periodic ones, and modernising trail commission rules.
The FCA’s own framing of the sequencing is direct: “With the targeted support rules now in place, our focus is on completing our outstanding policy work.” The consultation positions itself as the second leg of the reform — once the new middle tier is operating, the personalised tier above it is also lightened.
If the policy statement lands by end of 2026 as the FCA expects, the practical effect is a retail-advice landscape that is differently shaped to the one most firms still organise their permissions around. The bright line of the past 14 years becomes a graduated set of permissions.
The mechanism is worth being precise about. The change is being delivered through FCA Handbook rules and Consumer Duty interpretation. It is not being delivered through the Leeds Reforms Enhancing Financial Services Bill currently in front of Parliament, which is the structural primary-legislation consolidation Clarqo covered separately on Tuesday. The two are running in parallel: the Leeds Reforms move regulatory architecture, while Targeted Support and CP26/10 move retail conduct rules inside the existing architecture.
It is also distinct from the open question about general-purpose large language models giving consumers what feels like financial advice, which the FCA’s 2026/27 perimeter report flagged as a cross-sector issue. That perimeter question is about who counts as giving regulated advice. Targeted Support is about how many tiers of regulated advice exist for firms that already do.
For UK retail platforms, banks with execution-only investment offerings, pension providers, and the larger advice networks, the practical question over the next quarter is whether to apply for Targeted Support permission, how to define their consumer groups, and how their existing Consumer Duty assessments map onto a new activity. The FCA has, in effect, given them a new product surface and left it to firms to decide whether to use it.
The bright line of the RDR has not been deleted. It has been moved, and the move was made without statute.