Your ongoing-service record: what to log every year, per client

The ongoing-service record is the answer to the fee-for-no-service question. Four fields per client, per year, defeat it.

What the FCA says about ongoing-service records

Under the price and value outcome, an ongoing charge must be justified by the value delivered to this client, in their circumstances — not by a fee schedule. The FCA's Consumer Duty pages set out how price and value are tested.

In Enforcement Watch 2 the FCA describes firms that could not demonstrate what clients received for the charges they paid. The demonstration is the per-client record: service delivered, when, the value against the fee, and the next review.

The four fields

Every client on an ongoing charge gets all four, updated at each review.

Service delivered
What was actually done — the review, the call, the report. Concrete, not a vague 'ongoing support' entry.
When it happened
The date, so the record shows continuity and nothing slips through an annual gap.
Value against the fee
The justification for the ongoing charge in this client's circumstances — the value-for-money paragraph in log form.
Next review date
When the next review is due, so the trail is continuous and the annual cycle is visible.

The annual review that slipped, the value justification that lives in the adviser's head instead of the file — each is a flag the record prevents. Log it, and the record is the evidence.

Worked example: the record that answers “what did the charge buy”

Before

“Ongoing charge £2,400 — annual review undertaken.” The fee, the year, and a bare sentence. A reviewer cannot tell what, if anything, the charge bought; the answer lives in the adviser's memory, which is not a record.

After

Four dated lines: the April review meeting and the portfolio check against attitude to risk; the tax consideration from the June call; the value note — why £2,400 is fair in these circumstances this year; the next review booked for April. The charge is identical; the answer to “what did it buy” is on the file.

Common mistakes in the service log

Logging the fee without the service. A charge line with no delivery line is the fee-for-no-service pattern in miniature.
A value note that fits any client. “Ongoing advice and support” justifies nothing. The value note must be specific to this client and this period.
Dates that drift or go missing. The continuity argument dies when the record cannot show service through the year.
Next review date left to memory. The review that slips with no rescheduled date is a gap that the log was built to catch.

The four fields, and why a reviewer reads them

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 at all.
When it happened	The date of each item of service.	Whether service is continuous or a one-off.
Value against the fee	Why the charge is fair in these circumstances.	The price and value outcome in one paragraph.
Next review date	When the next review is due.	Whether the trail is continuous or breaking.

Frequently asked questions

What if the client declines the review but keeps paying?

Record it: the invitation, the decline, and the attempt to engage. That trail is the flag a reviewer looks for — documented inactivity reads differently from silence.

What counts as value for the fee?

The service delivered this period, in this client's circumstances: the review, the portfolio check, the tax consideration, the call that resolved a question. Specific, dated items — not boilerplate that fits any client.

Does the record have to be shared with the client?

The requirement is that the evidence exists and can be produced — to the client on request, to a reviewer on demand. A record that exists only in the adviser's head is not a record.

Your next step

Run one client's last twelve months through the four fields and mark every gap. Proven Duty keeps the service log, surfaces paid-but-not-served gaps, and dates every review. See pricing or talk to us.