The FCA is shifting the question from ’do you receive trail?’, to ’can you prove clients are getting value?’ Our research shows most clients think they are. The harder question is whether firms can demonstrate it.

Last week the FCA signalled its likely direction on legacy trail commission (pre-RDR payments from product providers that have persisted on older policies): no outright ban is expected, but firms should anticipate being required to evidence that ongoing adviser charges — whether legacy trail or post-RDR fees — are justified under Consumer Duty. It has also signalled that the scope of any consultation will be shaped by industry responses. Our annual Fee Benchmarking report surveys both advisers and their clients on what is charged, what is understood, and — crucially — what is valued.

What the consumer voice tells us

The majority of advised clients say the fees they pay for financial advice represent good value for money — and that holds even among those who have seen fees increase. When asked what would justify a fee rise, clients point to more personalised advice and better communication.

Trust and integrity of the adviser rank as the most important factor in the relationship — ahead of investment performance and fee transparency. The value is there. What is less clear is whether clients can always articulate it — and that is precisely the gap the FCA is focused on.

The risk is not that clients object to paying for ongoing advice. It is that they cannot always articulate what they are getting for it.

The consolidator dimension

Our 2026 report on the Consolidation of Advice will be published this month, and the trail commission/ongoing advice story lands at a particularly relevant moment. The firms we interviewed for this years report are no longer focused on how many businesses they buy — they are also asking whether they can demonstrate that every acquisition and every subsequent change for the client is genuinely in the client’s best interest. Consumer Duty has become an acquisition filter.

 “Integration feels like a real pressure point, particularly how firms evidence that integration decisions are in clients’ best interests.”

For the consolidators that moved fast on deals but slow on documentation, the trail commission/ongoing advice value question arrives at a difficult moment — and the risk of it becoming a claims-chasing issue is not one to dismiss.

The opportunity

The FCA has invited the industry to shape this consultation. The case for ongoing adviser charges — whether legacy trail or post-RDR fees is strong — our consumer data shows that clearly. The firms best placed to make that case are those that have built the infrastructure to demonstrate it, client by client, in a form the regulator can audit if needs be.

For consolidators, that is not a future consideration. It is a present one.

NextWealth’s Fee Benchmarking Report 2026 is available now. Get in touch to find out how our advice fee benchmarking data can support Consumer Duty value assessments.

Emma Napier, Consulting Director at NextWealth

FAQS:

1. What is the FCA’s stance on legacy trail commission?
   The FCA is not expected to ban legacy trail commission outright but is signalling that firms must prove ongoing adviser charges deliver clear client value under Consumer Duty.
2. What does Consumer Duty mean for ongoing adviser fees?
   Consumer Duty requires firms to demonstrate that all ongoing fees — including legacy trail and post-RDR charges — are fair, transparent, and provide measurable value to clients. 

3. Do clients believe financial advice fees offer value for money?
   Research shows most advised clients believe they receive good value, even when fees increase, particularly when advice is personalised and communication is strong.

4. Why is evidencing client value becoming a regulatory priority?
   The FCA is focusing on whether firms can clearly demonstrate and document the value clients receive, not just whether fees are charged — especially where clients struggle to articulate that value.

5. How does trail commission impact financial advice consolidators?
   For consolidators, trail commission adds pressure to prove that acquisitions and integration decisions are in clients’ best interests, making strong documentation and audit trails essential.