Fee for no service: how to monitor ongoing advice value
Fee-for-no-service risk is not a product problem. It is a monitoring problem.
The client pays an ongoing fee. The ongoing review happens — mostly. The record that it happened, what was delivered, and the value against the fee… that is where it frays.
When the FCA asks about ongoing services, the answer is your monitoring data — and it either exists or it does not.
What the FCA says about fee for no service
The price and value outcome requires that ongoing charges are justified by the value actually delivered to the client in their circumstances — not by a fee schedule. The FCA's Consumer Duty pages set out the four outcome areas, and price and value is the one where ongoing advice charges are tested: is the client getting value for what they pay, for this client, this year?
In Enforcement Watch 2 the FCA describes firms that could not demonstrate fair value to consumers or show they were actively monitoring consumer outcomes. The pattern is a monitoring failure as much as a product one: the fee was charged, the service record was thin, and the question — what was delivered for what was paid — could not be answered from the file.
The FCA's advice market survey puts the scale in context: it reports that 88% of retail clients receive ongoing advice. Fee-for-no-service risk is not an edge case in the book; it is the default product line for most of it.
What to log per client, per year
The ongoing-service record is four fields long. Every client on an ongoing charge gets all four, updated at each review.
Service delivered
What was actually done for the client this period — the review, the call, the report.
When it happened
The date, so the record shows the service is ongoing, not a one-off.
Value against the fee
The justification for the ongoing charge in this client's circumstances — not a generic statement.
Next review date
When the next review is due, so the trail is continuous and nothing slips.
Score your own book before someone else does. The annual review that slipped, the vulnerability flag nobody logged, the value justification that lives in the adviser's head instead of the file — each is a fee-for-no-service flag waiting to be found.
A worked example: the client record that holds up
Before
“Ongoing adviser charge £X per month — annual review due.” Nothing delivered on the record, no value note, no next-review commitment. A reviewer reading the file cannot tell what, if anything, the charge bought this year.
After
A service log: the review completed in April — annual review meeting, portfolio check against attitude to risk, tax wrap considered; the value against the fee justified in this client's circumstances; a vulnerability flag logged once and actioned; the next review booked for April so the trail is continuous. Four fields, one file, a full picture.
The charge is the same. The evidence is different — and the evidence is what the price and value outcome is tested on.
Common mistakes in ongoing-service monitoring
- The value justification lives in the adviser's head, not the file. Enforcement Watch's cases turned on what firms could not demonstrate from their records; an oral justification is not a demonstration.
- Generic value statements that would fit any client. “Ongoing advice and support” justifies nothing. The value note has to be specific to this client's circumstances and this period.
- Reviews slip with no rebooking record. A missed review is manageable; a missed review with no diary, no note, and no new date is a hole in the trail.
- Vulnerability flags noticed but never logged. The signal that appeared in a call, noted informally and never recorded, is the flag that the consumer support outcome exists to catch.
The ongoing-service record, field by field
| Log field | What it records | Why a reviewer reads it |
|---|---|---|
| Service delivered | What was done for the client this period. | Whether the charge bought anything. |
| When it happened | The date of each item of service. | Whether service is ongoing, not a one-off. |
| Value against the fee | Why the charge is fair in this client's circumstances. | The price and value outcome in practice. |
| Next review date | When the next review is due. | Whether the trail is continuous or slipping. |
Related reads
The four fields are the client-level end of the same evidence chain. See the Consumer Duty outcomes monitoring hub for how the chain is assembled, the annual assessment cycle for how the record rolls up, and the evidence checklist for what counts as proof at each step.
Frequently asked questions
What is fee for no service?
It is the situation where an ongoing charge continues while the promised service is not delivered, recorded, or justified for that client. The risk is a monitoring failure as much as a product one — the FCA's enforcement newsletter describes cases where firms could not demonstrate the value delivered against what clients paid.
What should the value justification say?
What was delivered this period, when, and why the fee is fair in this client's circumstances. It should be specific — the review that happened, the portfolio check, the tax consideration — not a boilerplate paragraph that would fit any client in the book.
What if the client declines the review but keeps paying?
That is the flag, not a detail. Record the declined invitation, the attempt to engage, and the decision. An unrecorded paid-but-not-served trail is where fee-for-no-service risk sits — and where it is hardest to defend.
Your next step
Run the book through the four fields once: service delivered, when, value against the fee, next review date — and mark every gap. Proven Duty tracks the ongoing-service record per client and surfaces the paid-but-not-served gaps before someone else does. Start a free trial or see pricing.