The FCA’s March 2026 pensions regulatory priorities report sets the contract-based agenda for the year ahead, with value for money, a new targeted support regime and legacy technology all landing squarely on GPP providers and IGCs, and at one remove on the advisers who work alongside them.
In reading this article you will understand:
- What the FCA’s four 2026 pensions regulatory priorities are, and how they relate to The Pensions Regulator’s parallel priorities for trust-based schemes.
- What’s expected of Independent Governance Committees specifically as the contract-based counterpart to trustees under the value for money framework, and on what timetable.
- What targeted support is under the Advice Guidance Boundary Review, how it differs from regulated advice, and what it changes for advisers and their employer clients.
The FCA published its 2026 pensions regulatory priorities report on 10 March 2026, organised around four themes: well-run schemes that provide value for money to savers, effective support for consumers, growth and innovation, and modernising pensions and long-term savings. This is the contract-based counterpart to tPR’s own strategic priorities for trust-based schemes, covered elsewhere in this series, and the distinction matters for corporate advisers. A significant share of the DC schemes advisers place employer clients into, group personal pensions (GPPs) and other workplace personal pensions, are FCA-regulated contracts rather than tPR-regulated trusts, governed day to day not by trustees but by Independent Governance Committees (IGCs) or, for smaller providers, governance advisory arrangements (GAAs). The FCA and tPR are converging on much of the substance, value for money chief among it. The legal mechanics, the timetable and the bodies doing the overseeing all differ, though, so advisers whose client bank spans both scheme types need to hold both pictures at once.
Value for Money: What’s Expected of IGCs
Value for money is the first and largest theme. Its mechanics are covered in more detail elsewhere in this series, so what matters here is who does the work on the contract-based side. Where trustees assess and publish for trust-based schemes, that duty sits with IGCs and GAAs for GPPs, who must judge a scheme’s investment performance, costs and service quality against the market and assign it a rating, with a poor enough result triggering a plan to move members out of an underperforming default. The FCA’s priorities report is explicit that firms shouldn’t wait for the first statutory assessments, expected from 2028 for larger schemes and across the market by 2029, before acting: it wants providers and IGCs preparing accurate data now, and it specifically flags legacy and closed products as the likeliest place a scheme turns out not to be providing value once the framework bites. Every GPP provider already publishes an IGC annual report, and it is worth reading now as an early signal of where a client’s scheme is likely to land rather than as a compliance formality.
Consumer Support and the New Targeted Support Regime
The second theme, consumer support, rests on a blunt finding: FCA research puts the proportion of DC pension holders aged 45 and over with a clear plan for taking their money at only around 25%. Its main policy response is targeted support, a new regulated activity created through the Advice Guidance Boundary Review, the FCA’s wider project to redraw the line between full regulated advice and generic guidance. Targeted support sits between the two: a firm can use information it already holds about a consumer to place them into a segment of people with broadly similar characteristics and needs, then give that segment a ready-made suggestion, without carrying out the individual suitability assessment full advice requires. The FCA set out near-final rules in PS25/22 on 11 December 2025, and its Board made the final rules on 26 February 2026. The application gateway for firms opened on 2 March 2026 and the regime went live on 6 April 2026.
Two things matter for advisers. First, targeted support is a firm-level permission, granted to providers, platforms, workplace pension operators and the like. It is not something an individual adviser can offer informally alongside their own regulated advice, and a client’s GPP provider applying for the permission doesn’t change what the adviser is allowed to say outside a full advice process. Second, it changes what a scheme member will encounter. Someone who has never taken advice may start receiving a provider suggestion that looks, to them, uncomfortably close to a recommendation. Explaining plainly why it isn’t advice, and how it sits alongside the service you provide, is a practical skill this reform makes newly necessary.
Growth, Legacy Technology and Goneaways
The third and fourth themes are shorter in the report but not in consequence. On growth and innovation, the FCA wants to remove unnecessary barriers to schemes investing in private assets, and has committed to consult on the pension charge cap and performance fees with a view to widening the range of asset classes available. It also plans a separate multi-firm review of Consumer Duty price and value practices in unit-linked pensions and savings. The report acknowledges the tension between opening up private markets and keeping members away from illiquid, hard-to-value holdings, rather than resolving it. On modernisation, the FCA’s central concern is what it calls the goneaways problem, consumers a firm has lost the practical ability to contact, alongside ageing administration systems and product complexity built up across decades of legacy back books. This is not abstract housekeeping. Accurate, current member data is the precondition for both value for money assessments and targeted support working as intended, so a provider that hasn’t modernised its records is starting the other two themes from behind.
What It Means for Advisers
Three things are worth doing differently as a result of this report. Start asking GPP providers directly what their IGC or GAA flagged in its last annual report, and what the provider actually did about it. A pattern of unresolved concerns is a better prompt for a scheme review than waiting for a formal VFM rating in 2028. Ask, too, whether a client’s provider intends to apply for targeted support permission and, if so, what it plans to say to members and when; a heads-up before members start seeing provider-generated suggestions lands better than fielding confused questions afterwards. And keep the two regulatory pictures distinct in client conversations. A corporate client with both a trust-based scheme and a legacy GPP, which is common after a provider switch, is working through two frameworks that converge on similar outcomes but run on separate rules, separate overseers and, for now, separate timetables. The FCA’s message to firms is that 2028 is a deadline to prepare for, not a date to wait for. The same goes for the advisers working alongside them.
Things to reflect on for CPD
- Which of your employer clients run GPPs or other workplace personal pensions rather than trust-based schemes, and do you currently read the IGC’s or GAA’s annual report for those schemes the way you’d read a trustee’s report?
- If a client’s GPP provider applies for targeted support permission, how would you explain to the scheme sponsor and its members the difference between what the provider can now suggest and the advice you provide?
- Where a GPP provider is running older, closed products for a client’s scheme, what would you ask about its plan for resolving goneaways and modernising its records ahead of the 2028 VFM timetable?
- How would you factor the FCA’s priorities into a scheme review now for a client whose group has both a trust-based scheme and a legacy GPP, given the two frameworks aren’t yet running to the same rules or timetable?
