HM Treasury has made the Financial Services and Markets Act 2000 (Regulated Activities) (Providing Targeted Support) (Amendment) Order 2026, inserting article 55A into the Regulated Activities Order to create the specified activity of “providing targeted support”. The instrument was made on 28 January 2026, laid before Parliament on 30 January 2026, and takes effect in two stages: from 23 February 2026 for regulator rule‑making, guidance, directions and authorisations (including the ombudsman scheme operator’s rules and guidance), and from 6 April 2026 for all other purposes across the UK. ([]())
In law, a firm provides targeted support when it uses information about an individual to place them in a group sharing similar characteristics or circumstances, and makes a recommendation presented as suitable for the individual on that basis. The recommendation may concern buying, selling, holding or exercising rights in a specific security, a structured deposit or a relevant investment. It is not a comprehensive review of the individual and is expressly outside article 53 (advising on investments). Firms must present, at the same time, a statement explaining that the recommendation is not individualised and setting out the group features used. (assets.publishing.service.gov.uk)
Implementation is phased. The FCA has published near‑final rules and opened a pre‑application support service, with the authorisations gateway scheduled for March 2026 and the regime expected to commence on 6 April 2026. The pre‑application service is designed to improve the quality of applications ahead of gateway opening and provide early feedback to firms. (fca.org.uk)
Targeted support adjusts the advice/guidance boundary by enabling group‑based recommendations without triggering the personal recommendation test. The regime carries bespoke conduct standards alongside the Consumer Duty and requires a distinct permission even for firms already authorised to advise on investments. (fca.org.uk)
Government policy is to mirror, where appropriate, the exclusions and exemptions that apply to article 53 so that legitimate activities can continue on a consistent basis under targeted support. Managers of UCITS and AIFs will need to seek permission rather than rely solely on the article 72AA exclusion if they wish to provide targeted support. (gov.uk)
Consequential changes align treatment across the RAO and other enactments so that suppliers of goods or services, group and joint enterprise arrangements, sales of a body corporate, overseas persons and certain insurance intermediation scenarios are treated consistently when providing targeted support. (gov.uk)
The Order also updates the Financial Services and Markets Act 2000 (Exemption) Order 2001 so that sector‑specific exemptions-for example for social housing, electricity undertakings, freight forwarders, policyholder advocates and Norges Bank-extend to targeted support. It also updates Companies Act 2006 definitions and other gateways to recognise the new activity. ([]())
Pension transfer safeguards are aligned by adding targeted support to the definition of “a regulated activity” in the 2021 transfer regulations (and the Northern Ireland equivalent), preserving the existing risk‑based conditions trustees apply when assessing transfers. ([]())
Marketing and data rules remain relevant. Government has acknowledged concerns about direct‑marketing constraints under PECR and indicates secondary legislation will enable workplace pension providers to deliver targeted support communications to members who have not opted out of direct marketing, alongside joint ICO/FCA work to clarify compliant approaches. (gov.uk)
For firms, the immediate tasks are preparing a variation of permission, defining the consumer groups to whom recommendations will be offered, testing the disclosure wording within real customer journeys, and designing monitoring to evidence outcomes. Use the FCA’s pre‑application support service ahead of the March gateway; final rules are expected to apply from 6 April 2026. (fca.org.uk)