FCA Adviser Meeting Evidence Checklist 2026: What Should Be Retained?

The client may explain why their circumstances have changed. The adviser may test their understanding, challenge an assumption, discuss capacity for loss, explain alternatives or agree that no action should be taken at this time.

Months or years later, the important question may not simply be what recommendation was made. It may be:

For financial advice firms, maintaining an effective record of client interactions can therefore be an important part of evidencing suitability, supporting compliance reviews and demonstrating the quality of the advice process.

This article provides a practical checklist of the evidence firms may want to capture and retain following an adviser-client meeting.

It is not a prescribed FCA checklist. The precise records required will depend on the service provided, the product involved and the applicable FCA rules.

1. When and how the meeting took place

Start with the basic context.

A useful meeting record should normally make it possible to establish:

• the date and time of the meeting
• who attended
• whether it was face-to-face, telephone or video
• the purpose of the meeting
• whether the discussion formed part of an initial recommendation, ongoing service or periodic review

For MiFID investment advice to a retail client, COBS 9A includes specific record-keeping requirements relating to the time and date on which investment advice was provided, the financial instrument recommended and the suitability report provided to the client.

The meeting record can provide useful supporting evidence around that formal documentation.

2. The client's objectives

A suitability assessment needs to reflect what the client is actually trying to achieve.

The record should therefore make clear what was discussed about matters such as:

• investment objectives
• intended investment period
• income or capital requirements
• retirement objectives
• liquidity requirements
• significant planned expenditure
• priorities and trade-offs between different objectives

Simply recording a generic objective such as “capital growth” may fail to capture the reasoning behind the advice.

A stronger record explains the client's circumstances and priorities in enough detail to understand why a particular recommendation followed.

3. Financial circumstances

The evidence should show which relevant aspects of the client's financial position were considered.

Depending on the advice being given, this might include:

• income and expenditure
• assets and liabilities
• existing investments and pensions
• cash reserves
• expected future income
• significant financial commitments
• taxation considerations
• ability to withstand investment losses

For MiFID suitability reports, COBS 9A requires firms to explain how a recommendation meets the client's objectives and personal circumstances, including their investment term, knowledge and experience, attitude to risk and capacity for loss.

Capturing the underlying discussion can provide useful evidence supporting those conclusions.

4. Risk and capacity for loss

A risk-profile score on its own does not necessarily capture the conversation that took place.

Where relevant, the meeting record should preserve evidence of discussions about:

• attitude to investment risk
• capacity for loss
• investment time horizon
• previous investment experience
• the client's understanding of potential losses
• any inconsistencies between stated objectives and risk tolerance
• how those inconsistencies were resolved

This can be particularly valuable where an adviser has challenged or clarified information provided through a questionnaire.

The evidence then shows not simply what the client's risk rating was, but how the adviser arrived at it.

5. Knowledge and experience

Where relevant to the suitability assessment, the record should capture the client's knowledge and experience of the products or investment risks being discussed.

That might include previous experience with:

• investments
• pensions
• market volatility
• investment losses
• particular product types
• complex investments

Again, context matters.

A client saying they have “20 years of investment experience” does not necessarily mean they understand every product or risk being considered.

6. What changed since the previous review

For an existing client, one of the most useful pieces of evidence is often what has changed.

That could include:

• employment
• income
• expenditure
• health or family circumstances
• retirement plans
• investment objectives
• risk tolerance
• capacity for loss
• assets or liabilities
• tax position
• planned withdrawals

Where a firm provides periodic suitability assessments, current COBS 9A rules require those assessments at least annually, with greater frequency where appropriate according to the client's risk profile and the financial instruments involved. Subsequent suitability reports can focus on changes in the relevant services, instruments or client circumstances rather than repeating everything contained in the original report.

That makes capturing changes accurately particularly important.

7. The recommendation — and the reasoning behind it

The final recommendation obviously needs to be recorded.

But the reasoning can be equally valuable.

The evidence should make it possible to understand:

• what was recommended
• why it was considered suitable
• which client objectives it addressed
• why the level of risk was appropriate
• relevant costs or disadvantages
• important alternatives considered
• why those alternatives were not recommended

For retail MiFID investment advice, COBS 9A requires the suitability report to outline the advice given and explain how the recommendation is suitable for the client and meets their objectives and personal circumstances.

A detailed meeting record can help demonstrate the evidence behind that explanation.

8. Questions, concerns and challenges raised by the client

This is an area where a contemporaneous meeting record can be particularly useful.

Consider retaining evidence of material questions such as:

• “What happens if markets fall?”
• “Can I access the money early?”
• “Why are you recommending this rather than leaving it in cash?”
• “What happens if I retire earlier?”
• “Why is this more expensive than my existing investment?”

The adviser's response may demonstrate important aspects of the advice process that aren't obvious from the final recommendation alone.

It can also help evidence the client's understanding of the proposed course of action.

9. Alternatives discussed

Good evidence does not always show a straight line from client objective to recommended product.

Advice frequently involves considering alternatives.

The record might therefore capture alternatives such as:

• retaining existing arrangements
• taking no action
• changing contribution or withdrawal levels
• using another product or wrapper
• changing investment strategy
• delaying a decision
• seeking specialist advice

Recording why an alternative was rejected can make the eventual recommendation considerably easier to understand.

10. What the client agreed

The meeting record should distinguish between what was discussed, what was recommended and what was actually agreed.

That includes any decisions to:

• proceed
• defer the decision
• provide additional information
• obtain further advice
• change an existing arrangement
• take no action

That distinction becomes important if the client ultimately chooses a different course from the original discussion.

11. Actions and follow-up

A good record should make the next steps obvious.

That may include:

• documents to be supplied
• additional information required from the client
• research to be completed
• suitability report preparation
• applications
• referrals
• follow-up meetings
• review dates
• actions owned by other team members

A clear record reduces both compliance risk and operational ambiguity.

12. Consumer Duty evidence

Meeting evidence can also contribute to the broader information firms use to assess whether retail customers are receiving appropriate outcomes.

The FCA states that firms need to identify appropriate data sources to evidence Consumer Duty outcomes and regularly assess, test, understand and evidence the outcomes customers receive. The appropriate evidence will vary according to factors such as the firm's size, client base and products and services.

Individual meeting records are not, by themselves, Consumer Duty compliance.

But across a client population they can provide valuable evidence of what customers were told, what they understood, what concerns they raised and what actions followed.

A practical adviser meeting evidence checklist

Following a substantive advice or review meeting, a firm may therefore want to be able to answer — do we have evidence of:

The appropriate evidence will vary according to the type of advice and applicable regulatory requirements.

But the underlying principle is straightforward:

From meeting conversation to compliance evidence

For many firms, the problem is not that the relevant information was never discussed.

It is that valuable detail from the conversation has to be reconstructed afterwards from handwritten notes, adviser memory and information entered into multiple systems.

TakeNote captures adviser-client conversations and turns them into structured records that can support the firm's existing advice and compliance processes.

The objective isn't to replace adviser judgement or determine whether advice is suitable.

It is to help firms preserve more of the evidence behind that judgement.

Sources

• FCA Handbook, COBS 9A — Suitability (MiFID and insurance-based investment products)
• FCA Handbook, COBS 9A.4 — Record keeping and retention periods
• FCA — Consumer Duty

This article is general information for financial services professionals and is not legal or compliance advice. It is not an FCA-prescribed or FCA-approved checklist. Firms should refer to the FCA Handbook and their own compliance function.