Consumer Scotland responds to FCA consultation on targeted support for pensions and investment decisions

Consumer Scotland published its response to the Financial Conduct Authority's consultation on supporting consumers' pensions and investment decisions on 25 August 2025¹. The consultation covers proposals for targeted support, a form of support sitting between generic guidance and regulated financial advice².

Consumer Scotland is the statutory body for consumers in Scotland, established by the Consumer Scotland Act 2020 and accountable to the Scottish Parliament². It said it welcomed the opportunity to respond and agreed that consumers must be able to invest for their future with confidence, with a full understanding of the relative risks and rewards of investment and the protections they benefit from².

The response cites FCA commissioned consumer research published alongside the consultation. It found that 36% of consumers exhibit under-investing behaviours, such as holding excess cash². On the existing advice landscape, the response notes that only 9% of adults received regulated financial advice in the last year, with 59% not accessing information, guidance or regulated advice on saving, pensions or retirement planning in that period². It adds that just 27% of those who hold investible assets, meaning £500 or more of cash or investments or a pension, have accessed any regulated or statutory information, advice or support in the last three years².

The response also reports consumer appetite for support: 54% of savers said they would welcome "a lot" or "a little support" in deciding whether to invest excess savings, and 40% of consumers cite a lack of knowledge as the main barrier to investing². Over half of non-investors in the research sample stated that they are unlikely to be investing in the future².

On redress, Consumer Scotland said having access to the Financial Ombudsman will mean consumers receiving targeted support have access to a free, informal and independent alternative to the courts for resolving complaints, and it supports the proposal that redress mechanisms follow the same complaints handling rules that already apply to other regulated forms of investment advice².

The response raises implementation issues, including the need to address undisclosed vulnerabilities such as poor mental health. It cites Money and Mental Health polling finding that while unwell, 63% of people found it harder to make financial decisions². It also refers to the FCA's recent review of consumer vulnerability, which found that consumers in vulnerable circumstances continued to experience poorer outcomes and were more likely to report slow responses and failures to find the information they required than other consumers².

Why it matters for households

The consultation concerns how people in the UK get help with decisions about pensions and investments, and whether a new category of targeted support would sit alongside existing information, guidance and regulated advice². The figures cited in the response describe how few adults currently receive regulated advice or access any regulated or statutory support, and how many hold cash rather than investments².

The response states that consumers with lower savings and investment pots, who may generate less in fees, may be viewed by some firms as a commercially less attractive segment, and recommends that governments and regulators work with firms so that all consumers, regardless of levels of saving and investment, have the same level of choice in terms of advice². It also notes that consumers with lower levels of financial knowledge are less likely to seek support than those with more knowledge².

On complaints, the response supports applying the existing complaints handling rules for regulated investment advice to targeted support, which would give consumers receiving it access to the Financial Ombudsman².

What happens next

The response was first published and last updated on 25 August 2025¹. The FCA consultation itself remains the mechanism through which the proposals would be finalised; no decision or implementation date is set out in the response. Consumer Scotland's recommendations include that firms follow inclusive design principles, supported by FCA guidance, and that the FCA provide guidance and monitoring on exiting and signposting processes where targeted support will not meet a consumer's needs².