PostGuard Editorial

FCA's New Investment Disclosure Rules: What IFAs Need to Change

The FCA is overhauling how advisers communicate investment costs. Here's what the proposals mean for your client communications.

FCA's New Investment Disclosure Rules: What IFAs Need to Change

The FCA announced this week that it's proposing to simplify how platforms, advisers and wealth managers communicate investment costs to clients. The regulator also issued a pointed reminder: communicate in plain English.

For IFAs who've spent years wrestling with MiFID II's percentage-laden disclosure documents, this might sound like welcome relief. But the proposals carry specific implications for how you present costs in everything from suitability reports to social media posts.

What the FCA is Actually Proposing

The current disclosure regime requires firms to present costs in multiple formats — percentages, pound amounts, cumulative figures over various time periods. The result, as many advisers know, is documents that technically comply but practically confuse.

The FCA's proposals aim to cut through this. While the full consultation details are still emerging, the direction is clear: fewer mandatory formats, more flexibility in how you present information, and a stronger emphasis on whether clients actually understand what they're paying.

This isn't the FCA going soft on disclosure. It's the regulator acknowledging that a 12-page cost breakdown that nobody reads isn't protecting consumers. A clear, concise explanation that clients actually engage with is.

The Plain English Warning

The FCA's reminder about plain English communication isn't throwaway guidance. It's a signal about enforcement priorities.

Look at recent Consumer Duty enforcement actions. The regulator has repeatedly focused on whether communications are genuinely understood by target audiences — not whether they technically contain the required information.

For IFAs, this means reviewing your standard documents with fresh eyes. That suitability report template you've used for three years? If it's packed with phrases like "the fund's ongoing charges figure of 0.75% is applied to the net asset value on a daily accrual basis," you're technically accurate but practically unclear.

Try instead: "This fund charges 0.75% per year. On a £100,000 investment, that's £750 annually, taken from your investment value."

Social Media and Marketing Implications

The plain English emphasis extends to your marketing and social media presence. The FCA has been increasingly active in monitoring financial promotions on social platforms, and "clear, fair and not misleading" applies whether you're producing a 40-page report or a LinkedIn post.

Consider a typical adviser post: "Our holistic wealth management approach delivers bespoke solutions tailored to your unique circumstances."

That's meaningless. It tells potential clients nothing about what you actually do or what it costs.

The FCA's direction of travel suggests posts like this will face greater scrutiny — not because they're technically non-compliant, but because they fail the basic test of clear communication.

A better approach: "We help professionals approaching retirement figure out if they can afford to stop working. Most clients pay around £2,500 for a full retirement plan."

Specific. Clear. Useful.

Practical Steps to Take Now

1. Audit your cost disclosures

Pull out your last five suitability reports. Show the cost sections to someone outside financial services — a family member, a friend. Ask them to explain what the client is paying. If they can't, your disclosures need work.

2. Create a jargon list

Document every technical term you use regularly: ongoing charges figure, platform fee, adviser charge, discretionary fund management. Write a plain English alternative for each. Use the alternatives in client-facing documents.

3. Review your social media

Look at your last 20 LinkedIn posts or tweets. How many contain specific, useful information versus generic marketing language? The FCA's emphasis on clear communication applies here too.

4. Test your templates

Before the new rules land, update your document templates. Remove redundant disclosures that add length without adding clarity. Focus on the information clients actually need to make decisions.

The Bigger Picture

This consultation fits into the FCA's broader shift under Consumer Duty. The regulator is moving away from prescriptive, box-ticking compliance toward outcomes-based regulation. Did the client understand? Did they get good value? Were they treated fairly?

For IFAs, this is largely positive. You'll have more flexibility in how you communicate. But that flexibility comes with responsibility. "We followed the prescribed format" is no longer a defence if clients didn't understand what they were paying.

The advisers who thrive under this regime will be those who've always prioritised genuine client understanding over technical compliance. If that's you, these changes simply formalise what you're already doing.

If you've been relying on template documents and boilerplate language, now's the time to change approach — before the new rules make it mandatory.

PostGuard automatically checks your social media posts against FCA financial promotion rules before you publish. Catch problems before the FCA does — start with 3 free checks at postguard.online

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