The new UK’s Advice Guidance Boundary Review has been pitched as a ‘once in a generation change’, but how is it going to change the wealth management landscape?
In 2022, the UK’s HM Treasury and Financial Conduct Authority (FCA) launched a joint initiative, the Advice Guidance Boundary Review (AGBR), with the goal of closing the advice gap. Earlier that year, the FCA had conducted a survey that found only 8% of UK adults had received regulated financial advice in the previous 12 months – up 2% from 2017. A few months later, the AGBR was announced with the goal of helping people make more informed and confident decisions about their finances.
In December 2023, the government issued three proposals on how it could better ensure people had access to affordable support to navigate financial and investment decisions. The first proposal is further clarifying the boundary. This would give FCA-authorised firms greater certainty they can give more support to consumers without moving into a personal recommendation. Proposal two is Targeted Support. This is a new regulatory framework that enables firms to increase the support they can give consumers. It is designed to be a middle ground between guidance and holistic advice. The final proposal, simplified advice, aims to give straightforward, one-off investment advice to consumers with less complex needs.
The regulation is being hailed as a major shakeup for the UK’s wealth management sector.
Jurgen Vandenbroucke, managing director at everyoneINVESTED, said, “The UK’s Advice–Guidance Boundary Review has become one of the most closely watched regulatory developments in wealth management. At its heart lies a simple but powerful ambition: to close the long-standing gap between regulated financial advice and generic guidance, and in doing so help millions of consumers who currently receive little or no meaningful support.”
Targeted support – a generational change?
While the whole of AGBR is generating excitement, it is the Targeted Support proposal that is attracting the most hype. The FCA described the change as a ‘once in a generation change.’ Targeted Support was launched on April 6th, 2026, meaning that authorised banks, pension providers and other financial firms can provide suggestions for groups of consumers with common characteristics.
Vandenbroucke echoed the FCA’s sentiment on the power of the new framework. He said, “for the first time, regulation is explicitly recognising the structural mismatch between consumer needs and the traditional advice model.” Millions of people are in need of support to make better financial decisions, but not everyone can afford regulated advice, he added. On the other side, financial institutions have been restricted by a binary framework that forces them to pick between high-cost advice or low-value generic advice.
“Targeted support has the potential to break this deadlock. If implemented well, it allows firms to provide meaningful, personalised direction without crossing into full advice, while remaining compliant. This is important not just for inclusion, but for trust.
“Consumers increasingly expect financial services to be as accessible and intuitive as digital payments or online banking. The current framework simply does not meet those expectations, and that is why this review could genuinely mark a generational shift.”
Another to be singing praise of Targeted Support is Fredrik Davéus, CEO and co-founder of Kidbrooke, who noted, “I say that as someone who is generally sceptical of industry hyperbole.”
A major reason for his excitement comes at the magnitude of its reach. He added, “The scale of the problem being addressed here is genuinely extraordinary.” The FCA estimates that 23 million customers in the UK are underserved when it comes to financial advice and guidance. Of these, nearly seven million hold at least £10,000 in liquid assets. “These are people the system has simply failed to serve.”
Davéus pointed to the Retail Distribution Review (RDR) of 2012, which aimed at improving the standards of retail financial services products and encouraging more people to invest. While Davéus believes the initiative was well-intentioned, an unintended consequence was making regulated advice commercially unviable for the mass market. He said, “Firms focused their models on wealthier clients where the economics worked, and everyone else was left with generic guidance or nothing at all. The advice gap that emerged has been well documented and widely lamented, but until now, the regulatory framework offered no credible middle ground.”
The FCA, which took over RDR from its predecessor the FSA, identified issues with the regulation and noted that many consumers continued to hold their money, rather than invest. This launched a process of trying to find ways to improve accessibility and solve this problem.
Targeted Support is a major step in that direction. Davéus noted that the firms can offer support to groups of consumers, without the full burden of individual regulated advice. Ultimately, this can provide a commercially viable way to serve those who have been historically left behind, he noted. Research from Boring Money claims Targeted Support could help bring 5.3 million adults, with collective assets of over £250bn, out of the advice gap.
Davéus added, “What makes this moment feel genuinely different is the convergence of regulatory intent and technological readiness. The infrastructure now exists to deliver personalised, data-driven financial support at scale and at a cost that makes it viable for the mass market. The regulatory framework is finally catching up.”
However, not everyone is convinced greater access is the main to investing is the greatest achievement of the AGBR. Hari Menon, global delivery and business head for wealth, capital markets, and AI at Intellect, explained, “It will be remembered as a turning point – but not because it introduced a new regulatory category. Its significance lies in what it corrects within the structure of UK wealth management.”
Wealth management in the UK, he noted, has operated on an implicit threshold that meaningful support starts when a client becomes viable for advice. Before this stage, people are offered information, rather than direction. He added, “That distinction has shaped behaviour more than regulation itself. People save and accumulate, but when it comes to decisions — allocation, risk, timing — they often proceed without structured support.” The millions of people with capital left uninvested are products of this poor structure of support.
Targeted Support will help to change this structure, not through extending full advice downwards, but building a legitimate layer between guidance and personalised advice. And its benefits will not end with greater access to investing. Menon said, “Greater participation can translate into a measurable expansion in UK AUM, indirectly strengthening the growth trajectory of the entire wealth industry. The Advice Guidance Boundary Review will change UK wealth management not by expanding advice, but by reducing the number of decisions made without support.”
Who are the real winners?
With AGBR being such a seismic shift for the wealth management sector, there could bring benefits to a range of players, but who will benefit the most?
For Vandenbroucke this will be the large digital platforms and the consumers, both of which are closely linked. The platforms already designed for scale, automation and consistent compliance will be best placed to operationalise targeted support efficiently, he noted. But it is the consumers that have historically fallen through the gap who will be the biggest beneficiaries. “For them, targeted support is not a downgrade from advice, it is access where there was none before.”
As for who Davéus sees being the real winners, it will largely come down to execution. If the regime works as intended, the primary winners should be the consumers. “That needs to be the north star for everyone involved.” Giving the consumers that have lacked the confidence, knowledge or support to invest access to credible and personalised guidance at no or low costs could “genuinely change retirement outcomes for millions of people,” he stated.
When it comes to firms, those with strong digital infrastructure, customer data and analytical capabilities to identify and segment consumers meaningfully will have the early advantage. Similarly, large platforms, pension providers, banks and digital investment services will be well positioned as they already hold client relationships and the required data. Davéus explained, “They can reach scale quickly and absorb the cost of providing free or subsidised support through cross-subsidisation, as the FCA anticipates many will do.”
The most interesting challenge, according to Davéus, is faced by traditional advice firms that have been offboarding clients in the £100,000 range due to the economics of ongoing servicing no longer stacking up, which has been accelerated by Consumer Duty. Targeted Support could provide these firms with a “genuine escape route.” He added, “It allows them to maintain a relationship and deliver value to clients who do not justify the cost of full regulated advice, while preserving the pathway to full advice when circumstances change.”
However, there is a risk with AGBR. There is a potential scenario where execution focuses too heavily on what is commercially convenient for firms rather than what is genuinely useful for consumers. Davéus said, “Consumer suspicion about conflicts of interest is real and legitimate with research showing it will be a critical factor in whether people trust and act on targeted support.”
Having only just been released, there is no way to know if it will live up to its promise. However, if AGBR delivers on its mission, Menon believes the first impact will be behavioural. There will be more individuals acting with confidence to move cash into investments, engage earlier with decisions and make decisions with clearer direction. He said, “In that sense, the consumer is not just a beneficiary, but the condition for success.”
On the side of firms, there is less certainty. Menon explained that platforms bring scale, data and the ability to embedded structured interactions across large client bases. Advisory firms deliver judgement shaped by experience, particularly when tough decisions require interpretation instead of information. “The advantage will not lie exclusively with either, but with those who can connect these strengths in a way that feels coherent to the client.”
He added, “What emerges is a continuum where advisory thinking extends beyond traditional client segments, without losing its discipline. That requires more than digitisation – it requires systems that can carry advisory logic consistently across different levels of engagement. The Advice Guidance Boundary Review will not be won by scale alone – it will be won by how well UK wealth managers scale judgment.”
The risk of a two-tier advice market
While Targeted Support aims to help provide more people with access to wealth management services, there is a worry it could inadvertently create a two-tiered advice market. This would see wealthier clients gaining access to full regulated advice and everyone else receiving a lesser, technology-delivered substitute.
Davéus believes this is a legitimate risk and one that the industry should be taking seriously. He said, “The concern is understandable: if targeted support is consistently framed as the ‘budget option’, it reinforces exactly the kind of inequality it is meant to address.”
However, deeming it as a lesser substitute misunderstands what good, targeted support should operate like. He said, “For someone with straightforward needs, a pension saver who needs to understand their contribution gap, or someone sitting on significant cash savings who simply needs a prompt and a clear pathway to act, targeted support that is well-designed, data-driven, and clearly communicated can be genuinely excellent. It does not need to be a pale imitation of regulated advice; it can be exactly the right intervention for the circumstances.”
This two-tier risk will take form if firms invest poorly in the quality of their targeted support infrastructure. This means treating it as a low-cost, low-quality product, rather than a purpose-built service. Poor communication could also create the two-tier mentality, especially if it is confusing and consumers struggle to understand what targeted support is.
Davéus believes that to prevent a two-tier market, quality and trust are essential. “If targeted support consistently helps consumers make better decisions and firms can demonstrate that, the stigma will not attach. The technology that underpins it needs to be genuinely sophisticated, not a superficial chatbot layered over a generic fund list, but a system grounded in real financial analytics, probability-based modelling, and a meaningful understanding of a consumer’s actual situation.
As for Menon, he understands the concern of a two-tier market, but it is nothing new to wealth management. He said, “The concern is understandable, but it assumes that the current market operates without layers, which has never really been the case.”
Economics and complexity have always shaped access to financial advice, with clients boasting larger portfolios receiving closer engagement and others navigating decisions with varying levels of independence, he said. “Targeted support does not introduce that structure; it brings definition to a part of the market that has so far been loosely served.”
Like Davéus, Menon believes the implementation of targeted support will define whether a two-tier market occurs. If these services are used as a substitute with simplified outcomes and a lack of clearly defined boundaries or pathways to fuller advice, the divide could be reinforced. On the reverse, if it is established as part of a progression that helps clients gain confidence and engage more deeply over time, it could transform the structure of wealth management.
Finally, Vandenbroucke also surmised that it will all come down to how targeted support is implemented. “At everyoneINVESTED we like the analogy of a positioning system: targeted support signals in what district the customer is located while full advice finds the customer’s exact location. Some customer needs can perfectly be met based on the district location. When designed correctly, it can deliver experiences that are intuitive, transparent, and fully compliant, often more consistently than human processes. But, as always, when done poorly, such technology can feel transactional, generic, or exclusionary.”
How to effectively implement targeted support
It is evident that the success of targeted support relies on how well firms can implement it. This means ensuring the technology infrastructure is well established and can support targeted support at scale. But what do firms actually need to have in place?
Menon argues the core components firms will need are data integration, segmentation and decisioning, areas that firms are already familiar with. However, this simply bolstering these areas is not enough to be successful. The AGBR is likely to evolve over the coming years, shaped through interpretation, supervisory feedback and practical realities. He said, “This creates a different expectation of technology. Systems can no longer be designed as fixed expressions of policy at a point in time. They must be capable of reflecting evolving regulatory intent, without requiring repeated cycles of redesign each time that intent is clarified or refined.”
As such, firms wishing to be successful should be working towards an adaptive model that does not just execute decisions but can interpret conditions under which those decisions remain appropriate. “The ability to adjust, assess alignment, and surface deviations becomes as important as the ability to deliver outcomes. In that sense, the industry is moving gradually towards systems that carry a degree of regulatory awareness within them – systems that are not only compliant but continuously aligned.”
Flexibility was not the only area of technology that needs attention for firms wishing to succeed with targeted support. Vandenbroucke emphasised the importance on bolstering digital investment solutions that are designed to support digital delivery, and do not simply replicate human advisory processes. “Copy-pasting adviser workflows into a digital interface does not work at scale, it creates friction and complexity. And most importantly, a cold automation of a human-based process performs poorly because it ignores the emotional component of investing.”
Beyond that, Vandenbroucke believes a credible targeted support model requires modular suitability logic, explainable decision frameworks, seamless client journeys, and strong governance embedded directly into the technology. He noted that while these standards have been met in other financial services areas, such as transactional banking and payments, it is lagging in wealth management.
Davéus, on the other hand, sees the task of preparing for targeted support as a much larger infrastructural shift than the others. He said, “This is where I think the industry needs to be most honest with itself, because the technology bar for credible targeted support is considerably higher than it might first appear.”
He added, “The FCA’s framework requires firms to pre-define situations, consumer segments, and ready-made suggestions, and to ensure there are reasonable grounds to believe each suggestion puts the consumer in a better position.”
As such, at a minimum firms will need the ability to segment customers meaningfully through structured data, transaction history, pension contributions, asset holdings and demographic signals. Additionally, they will need an analytical engine that can run forward-looking projections, such as picturing a person’s retirement based on the current trajectory and how these changes if they act, he said. Additionally, they will need an orchestration layer that allows AI and language models involved in customer communication to be grounded in calculations and not just creating responses freely. Finally, auditability is vital so they can demonstrate the data and logic that influenced any suggestion.
Finally, Davéus emphasised an ongoing monitoring capability is vital. Targeted support is not a one-time interaction; firms will be expected to track whether their support resulted in better outcomes. This will also mean continuous suitability monitoring and the ability to trigger follow-ups where circumstances change will also be important for success.
Davéus noted that larger platforms and banks with mature data infrastructure and existing digital advice capabilities are in a better position than they might admit. They have the client data and analytical foundations, so the gap is not technology foundations, but simply implementing the orchestration layer and the regulatory permissions framework. Smaller firms and traditional advice businesses, on the other hand, will have a much tougher time of preparing.
He said, “The honest truth is that firms should not attempt to build all of this from scratch. The smart approach is to integrate proven financial analytics capabilities through an API-first platform, one that already handles the stochastic modelling, suitability logic, and data infrastructure, rather than trying to reinvent that wheel internally. Time to market matters here.”
How will this shape the future of wealth management?
With AGBR poised to be a major shift for the wealth management sector, it raises the question of what the UK’s wealth management sector will look like in the next five years. For Vandenbroucke, if the regulation lives up to its promise, digital investing will be democratised and mainstream, similar to how digital payments are today. “Investing will no longer be perceived as a niche activity reserved for affluent clients with advisers, but as an integrated part of everyday financial life. If the Advice–Guidance Boundary Review succeeds, it will not just redefine advice, it will redefine access. And that moves us closer to a world where everyone is INVESTED.”
Menon believes that if AGBR can deliver as intended, its biggest impact of change will not be in product or channels, but in how consistently clients are supported as they make financial decisions. He said, “Engagement today remains episodic. Clients enter advisory relationships at distinct moments – when portfolios reach scale, when markets shift, or when life events demand attention – while outside those points, decisions are often deferred or made without sufficient context. That pattern has shaped both participation and outcomes.
“What begins to change is not the role of advice itself, but the continuity around it. Clients will continue to access full advice where complexity demands it, but will also receive structured, context-aware support at earlier and more frequent points in their journey – support that is proportionate in scope, yet precise enough to influence behaviour.”
This will have a compounding effect, including increased participation, earlier engagement and more informed decision-making. Ultimately, this will contribute to an expansion in UK AUM and bolster the overall growth trajectory of the industry, he said.
Finally, Davéus believes that if the regime is successful the distinction between digital guidance and support will become largely invisible to consumers. He said, “The experience they encounter will simply feel like helpful, timely, personalised financial engagement from the institutions they already trust, whether that is a pension provider prompting a contribution review, a bank suggesting a more appropriate savings vehicle, or an investment platform flagging a portfolio drift. The mechanics of whether that sits technically within targeted support or simplified advice will be a back-office categorisation, not something the client thinks about.”
Firms that will realise the most from this opportunity will be those that move early, invest into the right infrastructure and fostered customer trust through quality and transparency. He added, “The wealth management market of 2030 will be larger, more inclusive, and significantly more technology-intensive than it is today.
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