Suitability report template: the 12 sections and what each must prove
A suitable report has a shape: twelve sections, each with a job to do. Here is the anatomy and what each section must prove.
What the FCA says about the suitability report
Under COBS 9 a firm must take reasonable steps to ensure a personal recommendation is suitable — the report is where that duty is evidenced. The FCA's Consumer Duty pages and the publications library carry the FCA's guidance: the report is where reasoning, disclosure and checks meet.
The twelve sections
- 1
Client objectives
COBS 9.2.1RThe client's stated goals, in their own words where possible.
- 2
Personal and financial circumstances
COBS 9.2.1RThe accurate record the recommendation rests on.
- 3
Attitude to risk and capacity for loss
COBS 9.2.2RBoth recorded, consistent with the recommendation.
- 4
Vulnerability consideration
FG21/1Checked, outcome, reasoning — or explicitly ruled out.
- 5
The recommendation
COBS 9.4.7R(1)What is recommended, in terms the client can understand.
- 6
The rationale
COBS 9.4.7R(2)Why this recommendation suits this client — not boilerplate.
- 7
Alternatives considered
COBS 9.4.7R(2) / FG12/16Named alternatives and why they were rejected.
- 8
Charges and costs
PRIN 2A.4Initial and ongoing charges, with impact on returns.
- 9
Risks
COBS 9.4.7R(2) / Principle 7Key risks specific to this recommendation, plainly stated.
- 10
Disadvantages
COBS 9.4.7R(3)Possible downsides, including lost benefits or penalties.
- 11
Ongoing service
PRIN 2A.6What happens next, when, and the ongoing charge.
- 12
Plain-language disclaimer
PRIN 2A.5The report is a suitability document, not a promise of outcomes — stated clearly.
Every section maps to a rule and a rubric check. A report that clears the twelve is a report that answers the evidence question before it is asked.
Worked example: one recommendation across the twelve
The test: one recommendation through the twelve without a gap. Take a £50,000 multi-asset income fund.
Before
Objectives quoted but never used, an ATR score with no capacity test, no charges, a rationale that cites track record instead of the client's needs.
After
The same recommendation, fully dressed: objectives (income in five years); circumstances (salary, savings, dependants); ATR profile 5 of 10, capacity tested against a 20% fall; vulnerability considered and ruled out; the recommendation; the rationale tied to the objectives; two alternatives rejected with reasons; £1,240 first-year cost with impact on returns; risks, disadvantages, ongoing service and its charge; the plain-language statement.
Common mistakes in suitability reports
- Objectives quoted, then ignored. The rationale must use them.
- A risk section with no conclusion for this client — generic market risk is a caveat, not an assessment.
- Alternatives listed, not evaluated. Recording why they were rejected is the evidence.
- Costs in one place, value nowhere. Charges with no value argument fail price and value.
Six sections, their rules, and the evidence they must show
Rule labels are shorthand for the benchmarks on the FCA's Consumer Duty pages and in the publications library.
| Section | Rule it maps to | Evidence it must show |
|---|---|---|
| Attitude to risk and capacity for loss | COBS 9.2.2R | Both tests recorded separately, consistent with the advice. |
| The rationale | COBS 9.4.7R(2) | Why this recommendation fits this client. |
| Alternatives considered | COBS 9.4.7R(2) / FG12/16 | Options rejected, with reasons. |
| Charges and costs | PRIN 2A.4 | Total cost in pounds, initial and ongoing. |
| Risks | COBS 9.4.7R(2) / Principle 7 | Key risks specific to this recommendation. |
| Disadvantages | COBS 9.4.7R(3) | Possible downsides, lost benefits or penalties. |
Related reads
The report is the record the workflow checks. See the file review and suitability hub for how reports are reviewed, the annual review process for keeping it current, and the ATR-versus-capacity distinction for the section they test first.
Frequently asked questions
Is there a required format for a suitability report?
No statutory template exists. The report must evidence suitability — objectives, circumstances, risk and capacity, recommendation and rationale, costs, alternatives, risks. The twelve-section shape helps make sure none are missing.
How long should a suitability report be?
Long enough to evidence each section, short enough to stay readable. A short report that clears twelve beats a long one that skips three.
Who signs the suitability report?
The adviser who made the recommendation owns it, and the firm records the sign-off. A report with no named owner and no date cannot be defended.
Your next step
Run your last report against the twelve: which are done, which are empty. Proven Duty reviews against these sections. Start a free trial or see pricing.