In practice, CP26/10 represents a shift in how advisers are expected to exercise judgement, demonstrate suitability and deliver good outcomes under the FCA’s Consumer Duty. For advisers, the issue is not whether standards are changing (they are not), but how those standards are expected to be met.

From prescription to professional judgement

At the core of CP26/10 is the move away from prescriptive, process-led regulation towards a more principles-based framework. The consolidation of COBS 9 and 9A into a single chapter, alongside the move from gathering ‘necessary’ information to ‘sufficient’ information, signals that advisers are expected to tailor advice processes to the scope and complexity of each client’s circumstances. 

This does not represent any dilution of suitability requirements. Rather, the FCA is placing greater reliance on advisers’ professional judgement, underpinned by the Consumer Duty. Firms are therefore expected to clearly articulate and evidence why a recommendation is suitable, rather than relying solely on adherence to a standardised process. Advisers therefore gain flexibility in how advice is delivered, but with an increased obligation to evidence decisions clearly and consistently.

Rethinking ongoing suitability

One of the most significant proposals in CP26/10 is the move away from mandatory annual suitability reviews towards periodic reviews based on client needs. This reflects a long-held reality: an annual review may not always be the most appropriate solution for every client. For clients approaching retirement or drawing income, frequent and detailed reviews remain essential. For others with stable circumstances and long-term objectives, a rigid annual review cycle may not always add value for either party. Under CP26/10, firms must determine the appropriate review frequency and be able to justify that decision. Ongoing suitability does not disappear; instead, it becomes a question of demonstrating continued alignment between client objectives, risk profile and investment solution over time. This places greater emphasis on investment governance, not just the point-in-time advice process.

Suitability and investment governance revisited

As advice models become more proportionate and needs-based, suitability increasingly depends on consistency and clarity in portfolio construction. Where portfolios are managed in a fragmented way, evidencing suitability at scale can become complex, resource-intensive and difficult to standardise - particularly for disengaged clients.  

A risk under CP26/10 is not flexibility itself, but inconsistency in how that flexibility is applied across clients and advisers. This is where well-designed multi-asset outsourced solutions can play a valuable supporting role.

Why multi-asset investment solutions align with CP26/10

Multi-asset solutions do not remove adviser responsibility; advisers remain accountable for client outcomes. However, they can provide a framework that supports advisers in meeting CP26/10 expectations: 

Consumer Duty front and centre

CP26/10 reinforces that Consumer Duty underpins the entire advice framework. Advisers must continue to demonstrate fair value, avoid foreseeable harm and support clients in achieving their objectives. Consistent, outcome-oriented investment solutions can help underpin these requirements, particularly where client engagement fluctuates.

Doing the right things more effectively

CP26/10 is not about doing less. It is about doing the right things more effectively and being able to evidence that judgement. With the consultation closing on 22 May 2026 and final rules expected in the fourth quarter of 2026, advisers now have an opportunity to consider how they may make changes to their business models and service propositions.

At Aberdeen Investments, we believe this proposed direction of travel reinforces the role of well-governed, outcome-oriented investment solutions within the advice process. Our MyFolio range and Managed Portfolio Services (MPS) are built around clearly defined objectives and risk profiles, supported by a disciplined multi-asset investment approach.

In a world of periodic reviews rather than fixed annual cycles, strong central oversight, transparent portfolio construction and consistent reporting can support advisers’ professional judgement, freeing up more time for planning, engagement and long-term client outcomes.

More about MyFolio

For more information about the MyFolio fund family, or Aberdeen MPS, visit our website or speak to your local business development director.