The annual suitability review: six sections that keep it defensible
The annual suitability review is where ongoing suitability and value for money are evidenced. Six sections keep it defensible.
What the FCA says about ongoing suitability
COBS 9A keeps the suitability duty live for ongoing-service clients. The FCA's Consumer Duty pages frame the same duty around outcomes — the annual review is where the firm re-evidences suitability and value for money, in writing, for this client, this year.
In Enforcement Watch 2 the FCA describes firms that could not demonstrate what clients received for their charges. The six-section review is that trail.
The six sections
- 1
Client and file
Who, what, and when — the file this review updates.
- 2
What was delivered
The service provided since the last review — calls, reports, meetings, in a dated log.
- 3
Changes in circumstances
Any changes to the client's situation or objectives, and their effect on suitability.
- 4
Charges and value
The ongoing charge restated, and the value justification against what was delivered.
- 5
Outcome
Whether the recommendation remains suitable, or what changed and why.
- 6
Next review
The next review date and any triggers that would bring it forward.
The review that records the service delivered, restates the charge, and justifies the value defeats the fee-for-no-service question before it is asked.
Worked example: an annual review in six sections
A defensible annual review is six sections, each answering one question a reviewer will ask.
Before
“Annual review carried out. Portfolio remains suitable. Recommendation unchanged.” No record of what was delivered, no check on changed circumstances, no charges restated, no next review date.
After
Six sections: client and file; what was delivered (the April review meeting, the portfolio check, the tax consideration, dated); changes in circumstances (a redundancy, the effect on cash flow, the buffer agreed); charges and value (the £2,400 charge justified against that service); outcome (the recommendation remains suitable, with the reason); next review (April, plus the trigger that brings it forward).
Common mistakes in the annual review
- Re-listing the portfolio without updating the rationale. A list of holdings is not a check. The rationale must be re-tested.
- Restating the charge without justifying the value. “Ongoing charge £2,400” is a number, not an argument. The value must be shown in this client's case.
- Asserting “no change” where change happened. A redundancy, a house purchase, a bereavement — if circumstances changed, the file must show the recommendation was re-tested.
- Leaving the next review date blank. No next date means no continuous trail — the first thing a fee-for-no-service review looks for.
The six sections at a glance
| Section | What it must show | The flag if missing |
|---|---|---|
| Client and file | Who the review updates, and when. | A review that cannot be tied to a client or a date. |
| What was delivered | Dated service items since the last review. | A charge with no service record behind it. |
| Changes in circumstances | Changes and their effect on suitability. | “No change” where the facts say otherwise. |
| Charges and value | The charge restated and justified. | A fee line with no value argument. |
| Outcome | Whether the recommendation still fits, and why. | A conclusion with no reasoning. |
| Next review | The next date and any earlier triggers. | A broken trail with no next step. |
Related reads
The annual review is where suitability, service and value meet. See the file review and suitability hub for the full workflow, the per-client service log for the fields the review updates, and the 12-section report anatomy for the report the original advice produced.
Frequently asked questions
How often must an annual suitability review happen?
At least once a year for clients on an ongoing service, and sooner when circumstances change. The cycle and its evidence — the date, the work done, the outcome — are what a reviewer expects to see.
What if nothing has changed for the client?
A no-change review still has to show it is one: the check was run and the outcome recorded. An empty restatement reads as a tick-box exercise.
Does every review need a new recommendation?
No. Most reviews confirm the existing recommendation is still suitable and record why. A new one is needed where objectives or circumstances have made the current one unsuitable.
Your next step
Take one ongoing client and run the six sections before the review date. Proven Duty tracks the cycle, logs the record, and surfaces the reviews that slip. Start a free trial or see pricing.