HM Treasury has confirmed a new regulated activity, “providing targeted support”, to help consumers make pensions and investment decisions. The Order was made on 28 January 2026, laid on 30 January and comes fully into force on 6 April 2026; a short window from 23 February allows the FCA to finalise rules and accept authorisations ahead of go‑live. The policy aim is to widen access to clear, low‑cost help without rewriting the advice framework. (gov.uk)

What changes in law? A new Article 55A is added to the Regulated Activities Order so that “providing targeted support” becomes a specified activity. Where a firm delivers targeted support within that definition, it is not “advising on investments” under Article 53. The model is group‑based: firms use limited information to place a customer in a defined segment and make a recommendation presented as suitable because the customer is in that segment. HM Treasury signalled these features in its policy note; legal commentary confirms the 55A approach. (gov.uk)

This sits squarely in the advice–guidance gap. The FCA’s rules describe “ready‑made investment suggestions” for a defined segment rather than a full personal suitability assessment. Firms must evidence a reasonable basis for the suggestion at segment level; Consumer Duty still applies, but the suitability tests in COBS 9/9A are not triggered by targeted support. (macfarlanes.com)

Timing matters. The government’s consultation response indicates rollout from early April 2026, with the FCA’s authorisation gateway open in March and near‑final rules aligning to that timetable. The late‑February commencement in the Order allows the FCA, PRA and the scheme operator to make rules, give guidance and issue directions so firms can apply in time. (gov.uk)

Permissions are not automatic. Even if a firm already has Article 53 permissions, it must apply for the new Part 4A permission (or seek a variation) to provide targeted support. The FCA’s statutory six‑month clock for complete VOP applications applies, so early engagement via the FCA’s Pre‑Application Support Service (PASS) is pragmatic. (hoganlovells.com)

Scope is focused. Targeted support covers investments and pensions; mortgages and non‑investment insurance remain out of scope. Certain products and actions are excluded, such as recommending a specific annuity, non‑mass market or highly leveraged instruments, and pension consolidation-areas that would usually demand full personal advice. (hoganlovells.com)

Customers must be told what they are-and are not-getting at the point of recommendation. Firms need to state that the suggestion is not based on a comprehensive assessment, is not specific to the individual, and explain the segment characteristics used. HM Treasury’s response also notes a drafting correction in the SI from “relevant instrument” to “relevant investment”. (gov.uk)

Two quick examples bring it to life. A wealth platform identifies “first‑time investors” aged 25–40 with small, regular contributions and offers a low‑cost balanced model portfolio on the basis they fall within that segment-accompanied by the required statement. A workplace pension provider suggests a specific 2045 target date fund to members in their early forties who have not selected an investment path, again with the segment‑based disclosure at the same time.

For banks and fintechs, opportunity comes with boundaries. Structured deposits and investment‑linked products can feature in targeted support, but signposting to wrappers or to full advice remains guidance. Appointed Representatives are not currently permitted to provide targeted support without further legislative change, so principals should plan accordingly. (gov.uk)

Complaint handling will matter. The Order enables the “scheme operator” to make rules and give guidance for this activity; in FSMA, the scheme operator is the Financial Ombudsman Service. Robust records of segment design, negative target market, rationale and disclosures will help when outcomes are challenged. (legislation.gov.uk)

There are tidy‑up changes across the rulebook. The SI updates cross‑references so targeted support is treated consistently alongside Article 53 in places like the RAO exclusions, the Exemption Order, pensions transfer regulations and certain company‑law definitions. HM Treasury’s policy materials flagged the need for these consequential amendments. (gov.uk)

What to do now? Map your segments; test for fairness and bias; build the disclosure at the moment of suggestion; refresh PROD and Consumer Duty artefacts; and line up your permission application. For many firms, targeted support will be the scalable route to help the long tail of smaller accounts while keeping full advice for complex or high‑stakes decisions. The regime goes live on 6 April 2026-use February and March to be ready. (gov.uk)