TISA urges FCA to pause implementing fees and levies proposals to avoid unintended consequences, which could derail the rollout of Targeted Support
In its submission to the Financial Conduct Authority’s (FCA) consultation on Regulatory Fees and Levies: policy proposals for 2026/27 (CP25/33), TISA has urged the FCA to pause current proposals due to concerns that premature fee and levies implementation may ultimately undermine the aims of Targeted Support.
Without a clear understanding of projected costs or liabilities, TISA warns that the FCA’s proposals could disincentivise firms from providing Targeted Support, having unintended consequences for the rollout of Targeted Support.
In their response, TISA also highlighted concerns about the FCA’s proposals to base fees on eligible income, which would be difficult to implement. Additionally, presenting Targeted Support as a revenue-generating service would not only be unhelpful but also risk eroding consumer trust in the new service.
Commenting on the proposals, Sophie Legrand Green, Head of Policy at TISA, said:
“As Targeted Support could help millions more make better pension and investment decisions, we must get the accompanying fees and levies framework right, for both firms and consumers.
Without understanding the actual cost implications, there is a significant risk of the industry agreeing in principle to proposals, which, when applied, disincentivise them from providing targeted support, ultimately hindering its rollout.
Furthermore, positioning Targeted Support as solely a revenue-generating service by basing fees on eligible income, rather than one which aims to improve long-term financial outcomes for consumers, goes against the core values at the heart of this regime. Therefore, we urge the FCA to reconsider going ahead with this proposal”
Based on these concerns, TISA recommends that the FCA revisit the proposals once the regime has been introduced and tested, allowing the feed and levies framework to benefit from insights gathered. This could be part of the 2-year review of Targeted Support, which the FCA has already committed to.
Should the FCA still want to go ahead with a fees and levies framework, TISA proposes an interim approach where the FCA could introduce a simple model that is based on the number of consumers receiving Targeted Support, alongside a banded approach to support innovation.
Sophie Legrand Green also commented:
“We encourage the FCA to pause and allow targeted support to be introduced and tested before introducing a Fees and Levies Framework. The scheduled two-year review would be a perfect opportunity for the FCA to consult with industry and enable the Targeted Support to support better financial outcomes for consumers”
Notes to editors
- For a copy of the full consultation response, please contact tisa@tendoconsulting.co.uk
- TISA is a not-for-profit membership organisation committed to improving the financial wellbeing of all UK consumers by working collectively with the financial services industry to deliver solutions and champion innovation, for the benefit of people, our industry, and the nation.
- TISA has approximately 270 member firms involved in the supply and distribution of savings and investment products and associated services. Members include the UK’s major investment managers, retail banks, online platforms, insurance companies, pension providers, distributors, building societies, wealth managers, third party administrators, FinTechs, financial consultants, financial advisers, industry infrastructure providers and stockbrokers.