20th August 2026
While supportive of the FCA’s overarching objective of simplifying disclosures to help consumers make better informed decisions about their investments, PIMFA has raised concerns that a number of the proposals may have the opposite effect, given the complexity of the regime itself and the reported low levels of financial literacy across the general population.
Alongside this, PIMFA has highlighted a lack of clarity around how the proposed scope of some rules applies to various business models within the sector. The proposals signify a significant change for firms not currently in scope of FCA current guidelines and PIMFA is concerned that changes of this magnitude will require careful consideration and full consultation which the FCA is currently not providing for.
Cumulative impact of costs and charges
PIMFA has warned that the FCA’s proposals for the presentation of post-sale costs and charges present a particular area of concern.
Julia Sage-Bell, Senior Policy Adviser at PIMFA, says: “The proposal to use a different presentation basis from pre-sale disclosures is difficult to reconcile, as consistency will help support consumer education, manage expectations, and support good decision making. The proposals expect consumers to understand the difference between explicit costs and those integral to the running of the fund on a pre-sale basis, but on a post-sale basis, they are expected to understand that these costs have been aggregated.”
Scope and application of the requirements
According to PIMFA, the scope and application of many of the requirements in the consultation paper are unclear. Whilst the requirements may be proportionate, relevant and achievable for some businesses, the wider industry implications do not appear to have been fully considered.
Julia Sage-Bell, Senior Policy Adviser at PIMFA, adds: “The proposals appear to be geared towards vertically integrated firms and platform businesses, where data can be obtained and aggregated with ease, while consideration has not been given to how other firms will meet the requirements.
“The scope of the prohibition on the retention of interest and fees on cash holdings is also unclear, as the proposals make no reference to how it applies to firms with outsourced custody arrangements, model B propositions, vertically integrated firms, and discretionary fund managers. The same point applies to the disclosure requirements.
Cost disclosure reporting
PIMFA has also voiced concerns around the proposal to require firms to show the effect of costs on performance in regular post-sale reporting.
Julia Sage-Bell, Senior Policy Adviser at PIMFA, says: “We believe all cumulative effect of cost disclosure reporting should be removed, as it risks introducing an overriding focus on cost rather than performance or long-term returns.
“The proposals also contain a requirement to show the effect of costs and charges over the period during which the firm has provided the product to the client. This places a disproportionate burden on firms, who would need to gather historical cost and performance data and track it through switches, fund changes, sales, and additional investments. Given that firms would need to deploy significant resources to adhere to this requirement, and that the benefits for consumers are currently unclear, we have urged the FCA to omit this from the final rulebook.”
Other key points raised by PIMFA in its consultation response include:
- Disparity across the suite of costs and charges disclosures: PIMFA supports the FCA’s decision to display transaction costs in context as part of the product summary document. These costs are required to be disclosed as a separate charge in pre-sale reporting and then aggregated on a post-sale basis, resulting in the appearance of a steadily increasing cost figure. It is unclear how this journey will improve consumer understanding.
- Disclosing pre-sale costs of investing: PIMFA also supports the high-level proposals around how firms should disclose pre-sale costs of investing, welcoming the alignment with the product summary documents under the CCI regime. However, PIMFA has highlighted several areas where the proposals could be made clearer for firms producing the documents and easier for consumers to understand.
Julia Sage-Bell, Senior Policy Adviser at PIMFA, adds: “Transparency of costs and charges is absolutely critical to build trust within the industry. To achieve this, consumers need to be given relevant information at the appropriate points in the journey. Information overwhelm and complex explanations of concepts outside the consumers control will add to confusion rather than supporting informed decision making.”
-ENDS-
Notes to Editors
For further information or interview requests, please contact: PIMFA@boldspace.com
About PIMFA
PIMFA (the Personal Investment Management & Financial Advice Association) is the trade association for firms that provide wealth management, investment services, and financial advice and planning to everyone from individuals and families to charities, pension funds, trusts and companies.
The sector currently looks after £1.65 trillion in private savings and investments and employs over 63,000 people.
PIMFA represents both full and associate member firms. Full members provide a range of financial solutions including wealth management, financial advice and planning, as well as investment and execution services. They assist everyone from individuals and families to charities, pension funds, trusts and companies. Associate members provide professional services to the PIMFA community.
PIMFA leads the debate on policy and regulatory recommendations to ensure that the UK remains a global centre of excellence in the wealth management, investment advice and financial planning arena. Our mission is to help create a UK culture of thriving financial health through constructive advocacy, creating connections and practical support.
PIMFA was created in 2017 as the outcome of a merger between the Association of Professional Financial Advisers (APFA) and the Wealth Management Association (WMA) with a history as a trade association since 1991 – read more.
Further information can be found at pimfa.co.uk