What targeted support means for UK investment customers

On 6 April 2026, a new regulated activity called targeted support took effect across the UK. It allows an authorised firm to give an investment or pension customer a ready-made recommendation based on which group of similar customers they fall into, without carrying out the full individual assessment that regulated financial advice requires. HM Treasury established the regulated activity through a 2026 statutory instrument, and the FCA introduced the detailed rules that apply to it. Firms need specific FCA or Prudential Regulation Authority (PRA) permission before they can offer it.

Zopa Bank offers a practical example of the permission pathway and intended model behind the regime. On 19 May 2026, the bank announced that it had received permission to provide targeted support for investment products, describing itself as the first UK bank to do so. That is Zopa's own claim; it was not independently confirmed in the FCA material reviewed for this article. The announcement outlined an intended approach built around customers with similar financial profiles and goals, but it did not set out the segments Zopa would use, how it would exclude unsuitable customers, or the date its first targeted-support recommendation went live.

This matters beyond Zopa. Firms must obtain the relevant permission before they can provide targeted support. For a reader with money in a stocks and shares ISA, a pension or a general investment account, targeted support changes what a "nudge" or "suggestion" from a provider might now mean, and what it does not cover.

The gap this is meant to close

The FCA has said it estimated around 23 million UK consumers were underserved by the existing markets for advice and guidance. Its Financial Lives survey, covering the 12 months to May 2024 and based on 17,950 respondents, found that 8.6% of UK adults — 4.6 million people — had received regulated financial advice on investments, pension saving or retirement planning in that period. A larger group, 37% or 20.3 million people, had used information or guidance on the same topics, which is a lower bar than receiving a personal recommendation.

Those figures describe the advice gap the FCA was trying to narrow. They are not a prediction of how many people will use targeted support, and the FCA's own estimate of underserved consumers was published as a headline figure without the full methodology set out in the material reviewed here.

Three levels of help, compared

UK consumers now sit within three distinct categories of support, each with different legal consequences.

Targeted support sits between the other two. It can contain a recommendation, which generic guidance cannot, but it does not involve the comprehensive, individually tailored suitability assessment that regulated advice requires under the FCA's COBS 9 and COBS 9A rules.

How the segment model works

A targeted-support firm defines consumer segments around a shared financial need or objective, sometimes combined with common characteristics. Before it delivers a suggestion, the firm must use reasonable skill and care to confirm three things: that the customer is in the relevant situation, that they have all the segment's "including" characteristics, and that they have none of its "excluding" characteristics. The rules allow a person to be aligned to only one segment in a given situation.

Crucially, the firm must have reasonable grounds for considering its ready-made suggestion suitable for the individual customer in that segment. The suggestion itself is designed for the segment as a whole rather than built from a personal fact-find, but the firm still has to confirm the customer's actual alignment to the segment and consider relevant additional information it already holds, or could reasonably be expected to know, where that information might affect suitability. That duty exists, but it is narrower than the full picture a regulated adviser is required to build.

What the firm must tell you

Firms must label the service "Targeted Support" at the point they give a suggestion. They must disclose that the recommendation is not based on a comprehensive assessment of the customer's circumstances and is not specific to that customer. They must also explain the segment's including and excluding characteristics, and say whether the range of products considered was restricted — for example, to the firm's own products or those of its associates.

The Consumer Duty applies to targeted support, so a firm offering the service must design and deliver it in a way consistent with good outcomes for retail customers. The Duty does not oblige any firm to offer targeted support in the first place.

Targeted support is also not automatically free. The FCA wanted the framework to support services offered free at the point of use, but it has separately confirmed that firms can decide whether to charge, recover costs elsewhere, or cross-subsidise the service, subject to the FCA's fair-value requirements. A reader should not assume a "free" nudge has no cost attached somewhere in the product.

What targeted support does not do

It does not replace the suitability assessment behind regulated financial advice. It does not guarantee that a recommended fund, account or action is right for every person in the segment — only that the firm had reasonable grounds for considering it suitable for an individual correctly aligned to that segment, rather than a comprehensive personal assessment. And it does not remove the possibility that your own circumstances fall outside what the segment was built to capture.

Zopa's own announcement described targeted support as "not about telling customers what to do", and separately framed its permission as a middle ground between guidance and "full financial advice". Both phrases are marketing language rather than legal definitions. The FCA's rules expressly permit a targeted-support recommendation, and regulated advice itself can be delivered on a focused or simplified basis rather than only as a single "full" product — so the precise legal boundary is the one set out in the FCA's COBS 9B rules, not in a firm's own description of its service.

Zopa: permission confirmed, rollout not fully evidenced

As at 3 October 2026, Zopa's investment page advertised two ready-made funds, Balanced and Bold, both managed by Invesco, accessible through a stocks and shares ISA or a general investment account, with a minimum investment of £1 and a combined annual fee of 0.54% (0.40% to Zopa, 0.14% to Invesco). Zopa described its targeted-support approach as nudges, insights and support based on people with similar financial profiles and goals.

What the research for this article could not establish is when, or whether, Zopa has actually delivered a targeted-support recommendation to a customer. The 19 May 2026 announcement confirms regulatory permission and describes an intended approach; it does not identify a launch date, a live customer journey, or a first recommendation. Zopa's investment product itself had already been available before that announcement, under a separate rollout. Readers should treat "Zopa has permission to offer targeted support" and "Zopa is currently giving customers targeted-support recommendations" as two different facts, only the first of which is established in the sources reviewed here.

It is also not established in the material reviewed whether Zopa's "first UK bank" claim has been independently confirmed on the FCA Register, nor which specific customer segments, including or excluding characteristics, or product recommendations sit behind its service — Zopa has not published that detail.

Questions worth asking before you act on a suggestion

Before treating a targeted-support nudge as something to act on, a consumer could reasonably ask: which segment am I in, and on what information did the firm decide I belong to it? What circumstances, such as outstanding debt, limited emergency savings, a short investment timeframe, or a need to access the money soon, might the segment not account for? Does the firm only recommend its own products, or those of a related company, and has it said so? What would this cost, both in the investment's own charges and in anything paid for the targeted-support service itself? And would a conversation with a regulated adviser, who can look at your full financial position, be more appropriate than acting on a group-based suggestion?

The investment risk does not change

Targeted support changes how a recommendation reaches you. It does not change what happens to the money afterwards. Zopa's investment pages state plainly that the value of an investment can rise or fall and that a customer could get back less than they put in. Historical returns, including any performance figures a provider publishes, do not predict future returns. A regulatory permission to offer targeted support is not evidence that a particular fund or account is guaranteed, nor that it is suitable for every person placed in a segment.

Complaints and where to check further

A customer who is unhappy with a targeted-support recommendation can complain to the firm and, if unresolved, may be able to refer the complaint to the Financial Ombudsman Service. The FCA has indicated that the Ombudsman would assess such a complaint against the targeted-support framework — including the segment basis and disclosures the firm was required to give — rather than judging it as though it were full individual advice.

Readers who want to check a firm's permissions can look at the FCA Register, and MoneyHelper remains a source of free, independent guidance for anyone deciding whether to act on a targeted-support suggestion or to seek regulated advice instead. What remains to watch is whether Zopa, or any other firm now holding targeted-support permission, publishes further detail on its live customer segments, its first delivered recommendations, and how its disclosures work in practice.