Targeted Support, Six Months On

Targeted support went live on 6 April 2026. Six months on, the public record already tells a clearer story than any rules explainer could, with a credible slow start, a handful of firms moving in earnest, and several household names still deciding whether to bother. This piece is not another walkthrough of what targeted support is, as the law firms covered that thoroughly before launch. It looks instead at what the market has done with the regime since, and what that tells firms still on the fence.

The state of play

The FCA confirmed that 13 firms had applied for targeted support authorisation as the rules went live, a modest number against the size of the pensions and platforms market. Approval and an actual customer-facing launch are also turning out to be two different milestones, sometimes months apart. Here is where the names in the public record stand, as reported.

• Quilter. FCA approval received, among the first approvals confirmed.
• Royal London. Approved but not yet live, targeting the end of 2026 for its pension-specific launch.
• Legal & General. Live, having added targeted support to its proposition in May 2026.
• Monzo. FCA approval received, a neobank moving ahead of several established wealth platforms.
• Hargreaves Lansdown. Evaluating, reported to be building the business case but not yet committed.
• Barclays and AJ Bell. Evaluating, both reported as "eyeing" an offering rather than building one.

The split is telling. A mix of insurers, a challenger bank and one wealth platform have moved first, while some of the platform names you would expect to lead are still weighing it up.

Why the slow start was predictable

None of this should read as a regime in trouble. Trade press flagged a slow start as likely before the rules went live, and a Money Marketing survey since has found firms optimistic about targeted support in principle, but cautious about building it.

That gap between stated enthusiasm and deferred commitment is the real story of the first six months.

It is a familiar pattern to anyone who has watched a permissive new regime land, where the firms with the balance sheet and the existing infrastructure move first and everyone else waits to see what "good" looks like before spending on it themselves.

There is also a live debate about whether some firms should move at all. The editor of Financial Planning Today argued that targeted support carries real conduct risk for firms without the infrastructure to run it properly, a useful corrective to the more breathless "once in a generation" framing the regime received at launch.

What's actually proving hard

Strip away the legal analysis and three practical problems explain most of the hesitation among firms still on the sidelines.

The boundary is harder to run than to describe. Targeted support is defined against regulated advice by intent and process rather than by a bright line a customer journey can be cleanly built around. In practice every scenario a firm wants to support, such as "should I increase my pension contribution" or "is this fund right for someone like me", has to be mapped, scripted and tested to make sure it stays on the right side of the boundary. It then has to be re-tested whenever the product range or customer segments change, which makes it a live governance exercise rather than a one-off sign-off.

The monitoring and MI burden is heavier than a permissive-sounding regime implies. Firms need to evidence on an ongoing basis that targeted support is landing as intended for the segments it targets, not just that the rules were followed at launch. For a firm without an outcomes-monitoring framework already built for Consumer Duty, that is a second build on top of the first.

The cost/benefit case is uncertain for firms below a certain scale. Building the segmentation, content, monitoring and governance is a real cost. The return depends on customer volumes and the size of the advice gap in the firm's own book, which not every platform or provider can yet size with confidence. That uncertainty, more than any legal difficulty, looks like the real reason several well-resourced platforms are still at the "eyeing it" stage rather than the "building it" stage.

What this means if you're still deciding

For mid-size platforms, DFMs and SIPP operators, the six-month picture argues against two opposite instincts. The first is treating the slow start as a reason to deprioritise targeted support altogether, when the advice gap it is meant to address has not gone anywhere and the FCA has not softened its framing of it as a strategic priority. The second is rushing to match the early movers without the monitoring and governance infrastructure in place, which is precisely the scenario the conduct risk commentary above warns about.

The more useful question at this stage is not "should we do targeted support" but "what would need to be true of our data, monitoring and governance before we could do it responsibly". That groundwork has value with or without targeted support attached, and the gap between firms that have it and firms that don't is what is driving who has moved and who hasn't.

How Trescore can help

This is not a legal question. It is a proposition, governance and technology question, and that is where Trescore works. We help platforms, DFMs and SIPP operators work through the practical build. That means mapping which customer journeys could sit within targeted support, sizing the monitoring and MI framework it needs (often as an extension of existing Consumer Duty outcomes monitoring rather than a separate build), and making an honest cost/benefit case for the firm's own book before committing engineering and compliance resource.

If you are weighing up whether targeted support is worth building now, or want a second opinion on a business case already in motion, get in touch.