From April 2026, the FCA's targeted support regime (COBS 9B) creates a new category between guidance and full financial advice. Firms must define consumer segments with common characteristics and demonstrate that ready-made suggestions put consumers in a better position. Cross-provider data is the foundation it's built on.
For decades, the UK financial services industry has operated with a binary choice: generic guidance (which can't recommend anything specific) or full regulated financial advice (which requires a comprehensive suitability assessment and typically costs £1,000–£3,000+).
This leaves approximately 23 million UK consumers in the "advice gap" — people who need more than guidance but can't afford or access full financial advice.
The FCA's targeted support regime creates a third option. For the first time, authorised firms can:
Targeted support = segment consumers → design suggestions → deliver support → monitor outcomes. The critical first step is defensible consumer segmentation — and that requires data most firms don't have.
Under the FCA framework (PS25/22), firms offering targeted support must:
The regime is available to wealth managers, advisers, platforms, retail banks, insurers, SIPP operators, and asset managers. Initially, only directly authorised firms can participate — appointed representatives are excluded.
The targeted support regime sounds straightforward in theory. In practice, firms face a fundamental data problem.
To build defensible consumer segments, firms need to answer questions like:
The problem is that no single firm can answer these questions from internal data alone.
This is the core challenge: targeted support requires defensible segmentation, and defensible segmentation requires cross-provider behavioural data that reveals how consumers actually behave across the market — not just within one firm's book.
The FCA requires firms to prove three things about their targeted support:
Cross-provider behavioural data provides the evidence base for all three. Because Wealth Intelligence aggregates real consumer behaviour across 50+ UK financial providers, we can identify patterns that no single firm's internal data can reveal.
Real behavioural signals from consumers actively making financial decisions across multiple providers — not surveys, not estimates, not internal CRM data.
Our dataset captures the exact behavioural signals that targeted support segmentation requires:
These are exactly the types of consumer groups that targeted support is designed for — and exactly the groups that require cross-provider data to identify reliably:
Under the Consumer Duty framework and PS25/22 guidance, firms are expected to build targeted support segments using objective, evidence-based data, continuously monitor and update segments to reflect real consumer behaviour, and track outcomes to ensure interventions deliver fair consumer results. Our cross-provider behavioural dataset provides firms with the tools to satisfy all of these obligations.
| Requirement | How Our Dataset Addresses It |
|---|---|
| Objective, independent evidence | All data comes from first-party consumer interactions across 57+ providers. Segments are built on real decisions, not internal guesses or surveys. |
| Cross-provider benchmarking | Compare your client behaviour against a representative market-wide sample, ensuring your segments are defensible. |
| Lifecycle coverage | Data spans the full wealth lifecycle: accumulation, growth, protection, transfer and decumulation, supporting segmentation across all customer stages. |
| Continuous update & refresh | Our dataset is refreshed monthly, enabling firms to maintain segments that reflect the latest market behaviour. |
| FCA-aligned methodology | Every dataset comes with detailed methodology notes, allowing firms to demonstrate to boards or regulators how segments were defined. |
| Outcome-focused evidence | Segment design and interventions can be validated against actual consumer behaviour, supporting fair consumer outcomes under Consumer Duty. |
Use our cross-provider behavioural benchmarks to define segments objectively. Document methodology and thresholds in your compliance pack.
Update segments monthly or quarterly using the latest dataset refresh. Compare behavioural shifts to ensure segments remain accurate.
Monitor intervention uptake, contribution patterns, and withdrawal behaviours. Capture results to demonstrate impact and effectiveness of targeted support interventions.
Provide annual and ad-hoc reporting with dataset evidence, methodology, and outcome metrics. Demonstrate compliance with PS25/22 expectations.
Demonstrate segment rationale and outcomes to the FCA or internal audit with independent, documented methodology.
Monthly refreshes keep segments aligned with real consumer behaviour, ensuring ongoing compliance rather than point-in-time snapshots.
Identify gaps and opportunities relative to the wider market, not just your own book. Cross-provider context strengthens every segment definition.
Independent evidence removes the risk of conflicts of interest when defining support interventions. The FCA expects objectivity: third-party data delivers it.
Wealth Intelligence is more than a dataset. It is a compliance engine for targeted support under Consumer Duty. By combining first-party behavioural data, cross-provider benchmarking, and FCA-aligned methodology, firms can design, justify, and maintain evidence-based segments with confidence.
FCA publishes near-final rules and guidance for the targeted support regime.
FCA Board makes final rules for targeted support.
Firms can begin applying for permission to provide targeted support. FCA's pre-application support service (PASS) is available.
Firms with approved permissions can begin offering targeted support to consumers.