The Financial Conduct Authority has set out the next stage of its work on consumer access to investments, placing financial promotions, risk information, appropriateness checks and model portfolio services on a 2027 agenda. Its feedback statement, FS26/3, responds to last year’s discussion of how retail investing can become more accessible without weakening protections around higher-risk products.
This is a policy roadmap rather than a new rulebook. The regulator has not changed the current rules through the statement, nor has it committed to every reform canvassed in the earlier discussion. That distinction matters for investors and firms alike: the announcement identifies areas for review and consultation, but it does not itself broaden access to a particular investment or remove a protection.
A test of consistency in high-risk promotions
The first planned strand is a review of financial-promotion rules for high-risk investments. The FCA wants to examine whether products carrying similar risks are treated consistently, and to assess the harm that any mismatches may cause. The question is not simply how much advertising is permitted. Financial-promotion categories can affect whether a retail customer sees a product, what information they receive and what friction is applied before they can invest.
That focus responds to a practical problem in a market with increasingly varied products and routes to ownership. If similar economic risks are described or controlled very differently, a consumer may wrongly read the lighter treatment as evidence that one product is safer. Equally, a rule change that groups products too broadly could make long-term investment choices harder to understand. The FCA says it will work with stakeholders on the evidence before deciding whether alternatives could produce better consumer outcomes.
Risk information is not being abandoned
For mainstream investments, the regulator plans an early-2027 consultation on changes to rules and guidance for risk information. It says the work will be supported by consumer testing. The stated aim is information that is balanced, engaging and useful when a person is making a decision, rather than warnings treated as a compliance exercise detached from comprehension.
That is not a proposal to downplay loss or uncertainty. Investing necessarily involves risk, and the regulator’s policy direction remains that people should receive information that helps them understand both potential benefits and potential downsides. The consultation will be the point at which any detailed wording, scope and obligations can be examined. Until then, the statement should not be read as a settled change to the warnings firms use today.
Checking understanding before a purchase
The FCA will also review how appropriateness assessments work in practice. These assessments are a safeguard used in non-advised journeys for complex and high-risk investments: a firm collects information about a customer’s knowledge and experience to judge whether the investment is appropriate for that person. They are not the same as personal financial advice, but they are intended to introduce a meaningful check before an investor proceeds.
The review will consider the impact of the current model and the merits of alternatives, with stakeholder engagement planned in 2027. The issue has become more significant as investment journeys move online. A process designed to test a person’s understanding needs to remain credible where answers can be sought instantly elsewhere, while avoiding needless obstacles for consumers who do understand the product.
Model portfolios under separate scrutiny
Alongside the prospective consultations, the FCA has already begun a multi-firm review of model portfolio services. It is examining how firms that manufacture those services deliver good outcomes for consumers, and expects to publish its findings by the first quarter of 2027. The review is an investigation of current practice, not a conclusion that the services have failed or that new requirements have been decided.
For now, the clearest message is sequencing. The regulator is choosing targeted reviews and evidence-gathering instead of a simultaneous overhaul of every investment-access rule. Consumers should not infer an immediate entitlement to wider access, and firms should not treat the roadmap as final obligations. But the four workstreams give a useful indication of where future consultations and supervisory attention are likely to concentrate.
