Ongoing Advice Review Evidence File: A Checklist for UK Adviser Firms

An adviser firm proves an ongoing review happened with one evidence file per client per review: the invitation and any chasers, the review pack, the adviser's meeting record, the outcome letter and proof it was delivered. The FCA's 2025 review of ongoing services named weak record-keeping as poor practice.

That sentence is about proof, not about whether you did a good job. A review that happened but cannot be shown looks, to a regulator or an ombudsman, much like a review that did not happen. This checklist is about the paperwork around the review. It treats AI as a tool for admin drafting only, and it says nothing about what to recommend to a client, because that stays with the adviser.

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What the regulator actually said, and what it did not

The FCA published its findings on 24 February 2025 on a page titled "Ongoing financial advice services". Rather than rely on a summary, read the page yourself and check it for updates, because this area is under active review. The points that matter for an evidence file are these.

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• In the data it was given, suitability reviews were delivered in around 83% of cases. In a further 15% of cases, clients either declined or did not respond to the offer. In fewer than 2% of cases the firm had not attempted a review; the FCA said that would need to be put right and that redress is likely to be due in those cases.
• It listed good practice that includes clear client agreements setting out the nature and timing of the service, systems that schedule and offer reviews as agreed, and "appropriate record-keeping to make sure firms can evidence delivery".
• It listed poor practice that includes inadequate record-keeping, weak monitoring and too little management information for senior managers.
• It said firms should consider whether they can evidence delivery of every service they were required to deliver, and that firms carrying out proactive reviews should look back to 2018.
• Its good-practice list also includes policies to stop collecting fees where a client has not engaged with the service for a period of time.

One later development changes the timing, not the need for evidence. On 25 March 2026 the FCA published consultation paper CP26/10, which proposes replacing the annual suitability review with periodic reviews based on clients' needs and clarifying how firms support disengaged clients under the Consumer Duty. The consultation closed on 22 May 2026, and when this tutorial was checked in November 2026 the FCA's page said a Policy Statement would follow once responses were reviewed. Until final rules are published, the current rules apply: the FCA's page notes that where COBS 9A applies, ongoing suitability reviews must be carried out at least annually. Whatever frequency ends up in the rules, the file below still has to show the review was owed, offered, held and reported.

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It also noted the data were not a representative sample, so do not quote the 83% as an industry norm. The firm-level point is simpler: if a regulator asked you for the file for client X, year Y, could you hand it over in a few minutes?

Treat what follows as a practical admin guide, not compliance advice. Your compliance consultant or principal firm decides what your file must contain. Verify every requirement on the FCA page and in the Handbook sections it points to, such as the suitability chapters COBS 9 and 9A.

The file at a glance: five parts, one folder per client-year

Give every client a folder per review year, named the same way each time, for example C-0417 / 2026 / Ongoing review. Inside, five parts, always in the same order, so that anyone can open any file and know where to look.

Part 1: Entitlement, so you know what you owed

1. The signed agreement is in the file or linked from it. Why: you cannot show a service was delivered unless you can show what the service was. Check: open the file and find the signed page, not just a template.
2. The frequency is stated. "Annual review" is better than "regular contact". If the agreement is vague, note that on a cover sheet so that someone fixes the wording going forward. If the CP26/10 proposals become rules and you move some clients to a different review frequency, record the agreed frequency and the reason for it in this part, because the file can only prove delivery against what was promised.
3. The fee and what it covers are recorded. Why: the FCA's page ties charges to the services the client has paid for.
4. The cancellation right is evidenced. The page says firms can charge only if services and the right to cancel were properly disclosed. Check where that disclosure sits.
5. A cover sheet records the review year and due date. This is the single field your reminders and your management report depend on.

Part 2: The offer log

For the roughly one in six clients who do not engage, the offer log is the only evidence you have. Treat it as the most important part of the file, even though it feels like the least interesting.

6. Every invitation is stored as sent. Save the email or letter itself, not a note saying "invited". Check: you can see the date, the recipient address and the wording.
7. Every chaser is logged with date and channel. A sensible firm policy is a fixed sequence, for example invitation, reminder after 14 days, phone call after 28, final letter after 42. That sequence is an illustration of a policy you set, not a rule from the regulator.
8. Replies are saved, including refusals. A client who writes "not this year, thanks" has given you the evidence that protects you. Save the message.
9. Phone attempts have a call note. Date, time, outcome (spoke, voicemail, no answer) and who called.
10. Repeated declines are escalated. The FCA's page says that where a client has declined over a number of years, firms should discuss with the client whether the service is still in their interest. Add a flag at the second consecutive decline and put the conversation on the partner's list. Record what was decided about the fee too: the regulator lists a policy to stop charging clients who have not engaged for a period as good practice, so the file should show whether the fee continued and why.

A filled-in offer log

Client C-0417 | Review year 2026 | Due: 2026-03-31 | Adviser: Adviser B

2026-01-12  Email   Invitation sent, three suggested dates          Ref: msg-8841
2026-01-26  Email   Reminder, no reply                              Ref: msg-9012
2026-02-09  Phone   Voicemail left, asked to call back              Note: call-2217
2026-02-11  Email   Client replied, proposes 4 March                Ref: msg-9120
2026-03-04  Meeting Review held (see Part 4)                        Ref: mtg-C0417-2026
Outcome: Delivered within due month. Flag: none.

A second client in the same firm might end differently: invitation, reminder, voicemail, final letter, no reply by the due date. Status "Offered, not engaged", flagged for the partner, with all four attempts attached. That is a complete file. It is a very different thing from a blank folder.

Part 3: The review pack

The pack is the information that went into the meeting. The FCA's good-practice list says reviews should consider and record risk profiles, charges and the performance of existing investments to confirm they remain suitable or identify whether an alternative recommendation is needed.

11. Current valuation and the period it covers. Check: the date is visible.
12. Charges as actually applied. Platform, fund and adviser charges, summarised.
13. Performance against what the client was told to expect. Keep the comparison basis the same year to year.
14. Risk profile confirmed or updated. Record whether the client confirmed it unchanged. The FCA's good-practice list names circumstances, objectives, attitude to risk and capacity for loss as the things to bring up to date, so give each its own line rather than one tick.
15. Changes in circumstances. Health, family, employment, income, plans. A short questionnaire sent with the invitation produces these in writing.
16. Adviser's pre-meeting note. One paragraph on what the adviser intends to raise.

This is where AI can legitimately save time on admin. An assistant can turn a client's returned questionnaire into a tidy one-page "changes since last year" note, or reformat a valuation extract into your pack template. It should not decide whether the portfolio remains suitable. See the prompts tutorial for follow-ups and review prep for wording that keeps the model on the admin side.

Below is a client's returned questionnaire (client code only, no name).
Produce a one-page "Changes since last review" note with these headings:
Circumstances | Income and spending | Health | Goals | Anything unclear.
Quote the client's words where you can. Do not make recommendations.
Do not say whether anything is suitable. Mark gaps as "Not stated".

Illustrative output: five short headings, three populated, two reading "Not stated". The adviser's fix is to turn "Not stated" under Income and spending into a question for the meeting. The risk to watch for is an assistant that summarises a vague answer as if it were a clear one, so keep the original questionnaire in the file beside the note.

Part 4: The meeting record

17. Date, duration and attendees. Include anyone dialled in.
18. Topics covered, matched to the agreement. If the agreement promises a review of charges, the record should say charges were covered.
19. Client's stated changes and the adviser's response. In the adviser's words.
20. Decisions and whether a personal recommendation was made. The FCA's good practice includes communications recording that the outcome of a review was a personal recommendation.
21. Actions with owner and date. Both sides.
22. Consent for recording or AI note-taking captured. If you use a note-taking tool, the client should know. See the note-taker tutorial for what to check.

What a transcript does and does not do

An AI note-taker can produce a transcript and a draft summary within minutes of the meeting. Used well, it removes the hour of typing that makes advisers skip the record. Used carelessly, it creates a more dangerous problem: a polished summary that nobody read. Rules that work:

• The adviser reads the summary against their memory the same day and edits it.
• The record is the edited version; the raw transcript is kept only if your retention policy says so.
• Nothing in the summary is a new recommendation. If the model wrote "advised the client to increase contributions" and the adviser did not say that, it is deleted.

A realistic mistake: a summary stating "client confirmed risk profile unchanged" when the client had said "I think so, but my situation may change". The edit that fixes it is quoting the client: "Client said 'I think so, but my situation may change'; adviser to revisit in six months." Retention and archiving differ by tool, so check the archiving comparison before you rely on any tool as your record.

Part 5: Outcome and delivery

23. Outcome letter drafted from the adviser's record, then approved. Template wording for the admin sections is fine to draft with AI; the recommendation text is the adviser's.
24. Delivery proof. A sent email with its timestamp and recipient, a portal "delivered" entry, or a posting log for paper. Check: you can see when and how.
25. Client acknowledgement, where you have it. Not every client replies, which is why delivery proof matters.
26. The file is marked complete by someone other than the adviser. A second pair of eyes against this checklist catches missing parts before a regulator does.
27. The cover sheet shows the status. Delivered, Offered but not engaged, Declined, or Overdue.

The delivery log across the whole firm

Each client file proves one review. The firm-level log proves your system works, and it supplies the management information the FCA said senior managers need. One spreadsheet is enough:

The third row is the one that matters. "Overdue" with nothing in the Offered column is the fewer-than-2% case the FCA described. The log lets you see it in May instead of finding it in an audit.

Worked example: 220 clients, four advisers

Say a firm has 220 clients on annual ongoing services and four advisers. That is 55 reviews each, roughly one a week, plus the chasing. The monthly dashboard has four numbers: reviews due this month, offered, held, and letters sent. Suppose in a given quarter 66 reviews fall due. At month end the log shows 52 held, 9 offered and not engaged, and 5 with no offer logged yet. Those 5 get a call from the practice manager the next morning, and by the next month-end the "no offer logged" figure should read zero.

Suppose the practice manager then samples five files at random per adviser, 20 in all, against the 27 items above. If three files are missing delivery proof, the fix is a process one (the letter is sent from a personal inbox) rather than a discipline one. These figures are an illustration of the method, not benchmarks.

If you track leads and review dates in a CRM, the pipeline tutorial shows where its limits sit. For the wider picture of which admin jobs an assistant can take, see the further reading below.

Where AI helps the evidence file and where it must not

Before any client information reaches an AI tool, check that your data-protection basis, retention settings and supplier terms allow it, and that the tool does not train on your data by default on the plan you use. A principal firm or compliance consultant should confirm this for your set-up.

When an old file has gaps

You will find files that do not meet this checklist, especially from earlier years. Do not backfill them to look complete. Adding a meeting note today that pretends to be from 2021 is worse than a gap. Instead, add a dated "file review" note that states what is present, what is missing and what you did about it.

File review note, C-0388, review year 2022. Reviewed 2026-11-04 by Practice manager.
Present: signed agreement, valuation, outcome letter (dated 2022-05-18).
Missing: offer log, meeting record.
Action: asked Adviser A whether diary or email holds a record; none found.
Referred to compliance consultant on 2026-11-05 for a view on contact with the client.

That note is honest, dated and shows the firm noticed and acted. What happens next, including whether to contact the client, is a decision for your compliance adviser; the FCA page says firms should consider whether proactive contact is appropriate where harm may have been caused.

Keep these file review notes in one place, and count them. A firm that finds 12 gaps in a 20-file sample has a systemic question to take to its principals, whereas one gap in 20 is a tidy-up. The count, more than any single note, is the management information the FCA's page says senior managers need, and it costs nothing to keep.

Three situations to rehearse

A client says they never had a review. Open the file and read the offer log aloud to yourself. If it holds an invitation, a reply and a held meeting, you can answer in a minute. If it holds only a letter, you now know which part to fix across the firm.

An adviser leaves. Their clients' files must be readable by someone else. Check that meeting records are in the shared folder and not in a personal drive, and that the adviser's personal inbox does not hold the only copy of any invitation. Setting the sent-from address to a shared one for review invitations solves most of this.

A client changes the date late. Record the original due date and the new date and who asked for the change. A review held 40 days after due date at the client's request looks very different from one held 40 days late with no reason.

A first-month plan for a firm with no file structure

1. Week 1: create the folder template and the cover sheet; build the firm-level log from your CRM's review dates.
2. Week 2: pick the 20 clients whose reviews are due soonest and rebuild their files first, so the work is useful immediately.
3. Week 3: agree the chaser sequence and save the three template messages.
4. Week 4: run the first sample check and note what was missing.

Then decide, with your compliance adviser, how far to look back. The FCA's page suggests 2018 as an appropriate starting point for proactive reviews, but the scale of that work is a decision for your firm, not for a checklist. If you would rather map the process with someone, that is what my AI implementation consultation covers; you can reach me through the contact page. The original source is the FCA's ongoing financial advice services page, which is worth rereading in full.

Questions advisers ask about proving ongoing reviews

How far back should the evidence go?

The FCA's February 2025 findings said firms carrying out proactive reviews should look back to 2018, partly because of its record-keeping requirements and because many annual suitability review requirements came into force that year. Read the page for the exact wording and ask your compliance consultant what applies to your firm.

Will the annual review requirement be dropped?

The FCA has proposed it. Consultation paper CP26/10, published March 2026, proposes periodic reviews based on clients' needs instead of an annual one. It closed in May 2026 and a Policy Statement was still to come when this was checked in November 2026. Keep evidencing reviews at the frequency your agreements promise until final rules say otherwise.

What if a client never replies to review invitations?

Record every attempt with date, channel and wording, and keep any reply. The FCA's findings treat reasonable, proportionate attempts differently from no effort, and say persistent non-engagement should prompt a conversation about whether the service still suits the client.

Can AI write the review letter?

AI can draft admin text such as a meeting invitation or a note layout. The recommendation and the suitability judgement stay with the adviser, and the final letter should be read and approved by a person before it is sent.

Is a meeting transcript enough as evidence?

Rarely on its own. A transcript is raw material. The file should also hold the adviser's own record of what was reviewed, what changed and what was agreed, plus proof the outcome reached the client.

Further reads

• AI Agents for Financial Advisers: What They Can Do Without Advising — Which admin tasks an AI agent can take on safely.
• Copilot for Financial Advisers: Outlook, Teams and Excel With Records — Keeping meeting records inside Microsoft tools.
• Claude vs ChatGPT for Financial Advisers: Meeting Prep and Records — Comparing two assistants for prep and record drafts.
• Jump AI Set-Up for a Three-Adviser Firm: Templates, Consent, Review — Setting up an AI note-taker with consent captured.
• How Advisers Use AI to Prepare for Annual Client Reviews — How AI fits into the annual review cycle from prep to follow-up.
• AI Automation for Financial Advisers: Onboarding Without Re-Keying — Getting the ongoing-service terms right at the start.
• AI Tools and AI Development: The Complete 2026 Guide — the AI hub, including every tutorial in the AI-for-business series.

Sources: FCA multi-firm review page 'Ongoing financial advice services' (published 24 February 2025) and FCA consultation page CP26/10 'Simplifying the pensions and investment advice rules' (published 25 March 2026, last updated 1 June 2026), both read 4 November 2026.