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UK adds Targeted Support to RAO from 6 April 2026

The Treasury has created a new regulated activity: providing targeted support. Set out in an amendment to the Regulated Activities Order, it gives firms a formal route to make group‑based investment recommendations without crossing into personal investment advice. For retail investors, this should mean clearer signposting and nudges that are more relevant than generic guidance, but not as involved or costly as full advice.

The timeline is tight. The Order was made on 28 January 2026 and laid before Parliament on 30 January 2026. From 23 February 2026, the FCA can make or approve rules, issue guidance and start determining applications for permission. The regime then switches on for all other purposes on 6 April 2026 across the UK.

What counts as targeted support is precisely defined. A firm may use information about an individual to place them into a group that shares similar characteristics or circumstances, then provide a recommendation presented as suitable on the basis of that grouping. The recommendation can cover actions such as buying, selling, holding or redeeming securities, structured deposits or other relevant investments.

Crucially, when these conditions are met and a prescribed statement is given at the same time, the activity is not treated as advising on investments under article 53. The statement must make clear that the recommendation is not based on a comprehensive assessment of the person’s characteristics or circumstances and is not specific to them, while explaining the group traits used to frame the recommendation.

In practical terms, banks and building societies might segment customers by age and savings balance to prompt ISA top‑ups before tax year‑end, robo‑advisers could steer users in low‑engagement cohorts toward diversified starter portfolios, and insurers might flag investment‑linked options for customers sharing certain risk or time‑horizon characteristics. All of this would rely on clear disclosures that the nudges are group‑based rather than tailored advice.

Because targeted support is a specified activity, firms wanting to provide it will generally need permission under Part 4A of FSMA. The 23 February window matters: authorisations and variations can be applied for and decided ahead of go‑live, and approvals under Part 5 can be considered where relevant. The PRA may also exercise its Part 4A and Part 5 powers in relation to this activity for dual‑regulated firms.

The Order also updates a long list of cross‑references so targeted support is treated consistently across the regulatory framework. Exclusions that previously referenced article 53 are expanded to include article 55A in areas such as activities by suppliers, groups and joint enterprises, overseas persons, local authorities and insolvency practitioners. Related instruments are adjusted too, including collective investment scheme provisions, exemption orders and certain pensions transfer conditions.

Consumer protections are embedded in the disclosure requirement: the explanation must be delivered at the same time as the recommendation, spelling out that it is not comprehensive or personal. That pushes firms to keep records of the grouping logic, the wording shown to customers and when it was shown, alongside usual fair‑value and communications standards under FCA rules.

For compliance and product teams, the next six weeks are a build‑and‑test phase. Segment definitions and data inputs should be documented, the on‑screen or in‑app statements agreed with compliance, and sign‑off flows readied for FCA permissions. Staff training will need to explain where targeted support stops and full personal advice begins, and how to handle hand‑offs if a customer requests individual advice.

The Treasury notes that no impact assessment has been published, citing no or no significant impact on the private, voluntary or public sector. We’ll be watching for the FCA’s rulemaking and guidance from 23 February, which will set the operational tone. For now, firms have a clear pathway to scale “help that helps” without triggering suitability duties-provided they secure the right permissions and get the disclosures right.

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