Most adviser reviews stall on the same question: is this good value? It is a hard question to answer because there is no published price list for advice, no regulator-set fee, and no benchmark that tells you whether 0.8% or 1.2% is the right number for your circumstances. The Consumer Duty does not fill that gap. What it does give you is something more useful for a review conversation: a documented process that the firm must be able to show you.
The price-and-value outcome is one of four outcomes under the Consumer Duty, alongside products and services, consumer understanding, and consumer support. The FCA’s rules require firms to act to deliver good outcomes and to understand and evidence whether those outcomes are being met (PS22/9). That evidencing obligation is the lever. You are not asking the firm to justify its fee against a regulator’s number. You are asking it to show the reasoning it is already required to hold.
What fair value actually means — and what it does not
The FCA is explicit that fair value does not set a price or a level of profit. It aims to make sure consumers receive appropriate benefits relative to the price they pay (Price and Value Outcome: Good and Poor Practice update). That distinction matters at the start of a review. If you walk in expecting the Consumer Duty to tell you what your adviser should charge, you will leave disappointed. If you walk in asking how the firm assessed whether what you pay is reasonable relative to what you receive, you are asking a question the firm should be able to answer with documents.
The FCA’s own guidance also says a product or service that does not meet customer needs is unlikely to offer fair value, regardless of price. Benefits that are not realised in practice do not count. For a pre-retiree paying for ongoing advice, that translates into a direct question: what specifically am I receiving, and can the firm show that clients like me actually use and benefit from it?
Question one: was fair value assessed when decisions were made, or reconstructed afterwards?
This is the most revealing question in the set. The FCA says fair value assessments should reflect how firms make decisions in practice and should not be treated primarily as a retrospective exercise. They should be a record of how the firm assessed and delivered fair value from the outset. The regulator has specifically identified as poor practice assessments produced after the event to demonstrate that existing pricing and product design meet the requirements (same source).
In a review, ask when the assessment covering your service was produced and what decision it informed. A document dated to coincide with your request is a weaker signal than one that sits within the firm’s regular product and pricing governance. You are not auditing the firm. You are checking whether the reasoning exists as a standing record or only as a response to being asked.
Question two: did the assessment look beyond price?
The FCA’s findings across sectors show a recurring weakness: firms assessing value mainly by reference to price and stated benefits, without drawing on how the product is used in practice, whether customers understand it, and whether they are supported to use it effectively. The regulator says fair value should not be assessed in isolation from the other outcomes (same source).
For your review, that becomes a question about evidence rather than assertion. Does the firm hold information on whether clients understand the charges, engage with the service, and receive the planning outcomes they are paying for? A firm that can describe its client understanding and support arrangements in concrete terms is showing you the machinery behind the fee. A firm that can only restate the percentage is showing you the price and nothing else.
Question three: was your customer group considered?
The FCA says firms should understand which customer groups receive poorer value and be able to evidence how they monitor outcomes and take action where needed (unit-linked pensions and savings multi-firm review). It also says firms must not rely on customer inertia or behavioural biases to maintain pricing differences (Price and Value Outcome update).
This is where a pre-retirement client should pay attention. If you have been with the same adviser for a decade, hold a legacy platform, or have a portfolio that has not been reviewed against newer propositions, you may sit in exactly the group the FCA is asking firms to identify. The question is not accusatory: how does the firm identify clients who may be receiving less value than others, and what has it done when it found them? An answer that describes a process is reassuring. An answer that says all clients receive the same excellent service is not an answer to the question asked.
The FCA’s unit-linked review found that customers in older products were more likely to receive poorer value than customers in newer products, often because of older product designs, multiple layers of charges, and limitations in firms’ data. Legacy products often have complex charging structures with multiple components contributing to total cost (same source). That is a pensions and savings finding, not an adviser-charging finding, but the structural warning travels: layered, historic charging is harder for the firm to monitor and harder for you to compare. If your arrangements have accumulated layers over time, ask directly how the firm monitors value across them.
Question four: what happened when a risk of poor value was found?
The FCA is clear that identifying an issue alone is not enough. Firms must have a clear plan to address the risk, including defined actions, timelines and appropriate monitoring to assess whether the intervention has improved outcomes (Price and Value Outcome update).
This question separates a firm that has a live value framework from one that has a document. Ask for an example of a value issue the firm identified and what changed as a result. You do not need to know which client it was. You need to hear whether the loop closes. If the answer is that no issues have ever been identified, that is itself information — either the firm is unusually well-priced and well-run, or the monitoring is not finding what it should.
Question five: is the assessment kept current?
The FCA expects firms to keep fair value assessments under regular review as part of ongoing monitoring, with frequency and depth proportionate to the product or service. Firms should update assessments where there are material changes or emerging risks, such as changes to pricing, product features or distribution, or evidence that customer outcomes may be deteriorating (same source).
In practice, ask what triggers a review of the value assessment covering your service. A scheduled annual review is a baseline. A firm that can also describe event-driven triggers — a platform repricing, a change in the advice proposition, a shift in client outcomes — is showing you that the assessment is wired into how it operates rather than filed and forgotten.
What the FCA’s sector reviews tell you about the questions to ask
The regulator’s multi-firm reviews are not about adviser charging, and it would be wrong to read them as findings against advisory firms. But they are useful as illustrations of the failure modes the FCA is watching for, and those failure modes are the ones your questions should probe.
In the contracts for difference review, the FCA found many firms’ fair value assessments gave only limited consideration to costs paid by consumers other than execution spread costs. Some assessments drew from a narrow or inappropriate peer group, including comparison with firms based outside the UK. Many firms had not adequately considered indicators of value such as consumer complaints and satisfaction metrics (CFD multi-firm review).
Translate that into an adviser review and the questions become sharper. Does the value assessment consider the total cost you bear — advice fee, platform charge, fund costs — or only the advice fee? Is the peer comparison against UK-regulated firms offering a comparable service, or against a broader and less relevant group? Does the firm look at complaints and client satisfaction as indicators of value, or only at price? None of these are gotcha questions. They are the questions the FCA’s own findings suggest a well-run firm should be able to answer.
A practical review script
You do not need to interpret regulation to use this. Five questions, asked in writing before or during the review, will tell you a great deal about whether the firm’s value framework is live:
- When was the fair value assessment covering my service produced, and what decision did it inform?
- Beyond price, what evidence did the assessment consider — client understanding, use of the service, and outcomes received?
- How does the firm identify client groups receiving poorer value, and which group am I in?
- What value issues has the firm identified, and what actions, timelines and monitoring followed?
- What triggers an update to the assessment, and when is the next scheduled review?
Ask for the answers in writing. A firm that can respond with specifics is demonstrating the evidencing obligation in action. A firm that responds with reassurance rather than records is telling you something too — not that it has breached the Duty, which only the regulator can determine, but that the reasoning you are entitled to see is thin.
What to do with thin answers
The appropriate response to a vague answer is not to assert a breach. It is to ask again, in writing, and to note what you receive. If the firm cannot describe how it assessed value, which client groups it monitors, or what it did when it found a problem, you have a decision to make about whether the relationship still meets your needs. That is a commercial and personal judgment, not a regulatory one.
It also helps to place the review in the wider sequence of decisions you are making in the run-up to stopping work. The adviser relationship is one input; the timing of your stop-work date, the funding of the bridge to State Pension age, and the tax-aware wrapper decisions are others. A useful starting point for the sequencing question is the question you should be asking years before you retire, which sets out why the order of these decisions matters more than the precision of any single one.
What the Consumer Duty does not give you
It is worth being direct about the limits. The Consumer Duty does not give you a right to a specific fee level, a personal refund, or a regulator-endorsed benchmark for your circumstances. It does not make your adviser’s charges fair by operation of law. What it does is require the firm to hold and be able to show the reasoning behind its pricing and service decisions, and to act when it finds poor value. Your leverage is procedural: you can ask for that reasoning, and you can judge whether the answer is substantive.
That is a quieter form of power than a price comparison, but for a professional or couple with £300k or more across pensions, ISAs and property, it is the more relevant one. The question is not whether the fee is the lowest available. It is whether the firm can show that what you pay is reasonable relative to what you receive, that it knows which clients may be getting less, and that it acts when it finds out. Ask those questions at your next review, in writing, and keep the answers. They will tell you more than any headline percentage.