Your Targeted Support roadmap
The headlines around Targeted Support are enticing. But as with all changes to the regulatory landscape, realising the strategic potential of the service will depend on getting to grips with its operational complexity. To support our clients with the design, build, authorisation, and deployment of their initial solution, we have defined a set of core activities intended to address four fundamental questions. There will inevitably be nuances in the way firms execute these activities but collectively they provide the basis to successfully navigate the introductory phase of Targeted Support.
"Targeted Support could transform how retail customers make pension and investment decisions, but the path won’t be linear. Firms must navigate complex solution design, secure regulatory approval, and learn quickly from early customer engagement. These steps lay the foundation to scale across use cases and embed mutual value."
Guy Munton, Partner, expert in Regulatory Compliance
1. Develop your Targeted Support strategy
The question of whether to offer Targeted Support is far from rhetorical. There’s inherent complexity in building a compliant and engaging proposition as well as significant associated build and run costs. Firms should think carefully and agree how Targeted Support aligns with existing propositions, its internal and external purpose, and ultimately the long-term business case. There is also a need to establish what the firm wants to achieve in its initial solution development.
Critical actions you should take
Establish a ‘North Star’
- Create a business working group to determine the explicit purpose of Targeted Support for the organisation and the customer and determine how Targeted Support will sit alongside existing advice-guidance services
- Subsequently, agree and formalise the guiding strategic principles that will underpin Targeted Support and define the associated success criteria that you will evaluate against in the short- and long-term
Create the business case
- Expand the working group to ensure cross-functional representation in the development and challenge of the business case
- Conduct a current-state capability assessment to identify and size high-level requirements across multiple phases of solution maturity and scale
- Model business case inputs and outputs against the defined maturity phases, recognising the limitations of assumptions around scaling use-cases beyond the initial phase to launch
Prioritise use-cases / situations
- Create a long-list of potential situations to evaluate, utilising data from Consumer Duty oversight to identify potential scenarios of harm or segments for whom outcomes can be materially improved
- Create a scorecard to apply agreed short-term success criteria to each of the situations in the long-list. It’s likely that timeline ambitions will have a significant influence on the criteria weighting
Challenges to be aware of
Setting a realistic baseline of understanding will be complex
Be clear on what Targeted Support is and what it’s not and be upfront about the complexities, constraints, and the nature of the journey to mature it
Establishing agile decision‑making governance will involve negotiation
Set up governance with the understanding that you will need to move quickly but with the right executive support for critical decisions
A quest for perfection will derail the strategy
This is an iterative, agile development process so understand the limitations of key assumptions and stay true to your guiding principles
2. Build your Targeted Support solution
Firms have been working hard to identify initial Targeted Support use cases that will both make an impact in early deployment and stress‑test how well existing infrastructure delivers the service. However, there’s a natural risk that the need for learning is pushed aside in the rush to deploy something to customers. The build process should continually assess the materiality of emerging constraints and complexities, as well as the limitations of how the initial solution responds to them.
Critical actions you should take
Map customer journey (inc. exits)
- Define a solution blueprint format for the development of Targeted Support journeys and determine whether it sits alongside or will be integrated with ‘non-Targeted Support’ journey maps
- Establish protocols for exiting customers from Targeted Support, including exits through non-digital channels and for engagement with vulnerability characteristics
Build cohort data model
- Define the situation target segment characteristics and identify the data attributes that map to those segment characteristics (and those that require exclusion)
- Assess the gaps in your data model and determine the approach to closure (assumptions vs. customer validation)
Enhance digital delivery platform
- Assess the technical requirements for platform enhancement and synchronise development work with delivery dependencies from across the rest of the project
- Execute the functional and technical build within the chosen digital environments
Source outcomes data and set thresholds
- Identify and source critical data related to the defined ‘better’ outcome and capture the narrative that explains the relationship of that indicator and its performance to the desired outcome
- Back test different data elements to understand relative sensitivity to key assumptions, prioritise data for outcomes monitoring and conduct scenario testing on proposed intervention thresholds
Test end-to-end service journey (UAT and customer)
- Agree test scripts and sequencing, as well as acceptance criteria that refer to the established success criteria
- Undertake testing, ensure agile feedback, and update mechanism to address test outcomes
Challenges you should be aware of
Designing the customer journey will test digital‑only delivery limits
Acknowledge the reality that intended or unintended step-outs or exits will necessitate thinking and accommodation of non-digital processes
Building segment models may spark friction between first‑ and second‑line teams
Get into the detail of segmentation early in your development process as it will be the most contentious design decision of the build with multiple outbound dependencies
Solution testing must be timed with the approval of all testing standards
Don’t be tempted to dive into customer testing too early. Be clear about how testing will adhere to standards developed for the overall service framework and stand-up to regulatory scrutiny
3. Design your BAU service framework
The FCA’s stated areas of focus within the authorisation process mean that firms need a well‑defined understanding of how the service will be operated and governed in BAU. At the same time, the inherent uncertainty around how Targeted Support will scale means that this view will inevitably rest on several key assumptions. Firms should therefore carefully consider their operating‑model transition states and how sensitive these are to the factors underpinning those assumptions.
Critical actions you should take
Design operating patterns
- Develop business-initiated and customer-initiated engagement patterns that can be consistently applied across all potential use-cases and situations
- Capture the current vs. future capability requirements to deliver each step of the engagement
Develop data validation approach
- Formalise controls related to segment data quality / integrity as well as the governance that supports those controls
- Formalise protocols for the mapping of data to segment characteristics and the sourcing and processing of customer data to populate the model
Establish governance and control framework
- Define the touchpoints between your governance of the Targeted Support service, individual use-cases or situations deployed and products that are suggested to a segment
- Identify and describe the controls required through the Targeted Support lifecycle and agree ownership and monitoring standards for the oversight of control effectiveness
Define outcomes monitoring standards
- Establish the touchpoints between the monitoring of Targeted Support outcomes and the Consumer Duty outcomes framework
- Define how governance will support intervention and action on Targeted Support outcomes at a different tempo to Consumer Duty
Develop ex-post / ex-ante testing approach
- Design a holistic testing approach and methodology for Targeted Support that covers pre- and post-launch testing
- Agree testing roles and responsibilities, alongside governance of testing outcomes and actions
Challenges you should be aware of
Digital channels will shape reactive engagement only partially
Acknowledge the limitations of your ability to validate reactive engagement patterns and build out a deep understanding of the capabilities required to support them
The service–product governance relationship will be complex
Stakeholders will want to limit the impact on existing product governance, but there are potential implications for target market definitions and distribution strategies, if Targeted Support suggestions don’t perform as expected
Targeted Support thresholds and timelines will materially diverge from Consumer Duty
Targeted Support won’t fit neatly into existing good outcomes frameworks because suggestions intuitively demand longer outcome assessment cycles
4. Obtain your Targeted Support authorisation and deploy your solution
As part of its commitment to move at pace and offer more flexible engagement, the FCA envisages targeted support authorisation as a fundamentally different experience for firms. In the spirit of agile, iterative development, applicants should use the Pre‑Application Support Service (PASS) to reinforce key development milestones and drive further refinement of their solution. However, the journey doesn’t end with authorisation and initial deployment. Detailed planning for the first 90 days of targeted support is critical—alongside formalising commitments for phase two, as use cases are scaled, underlying capabilities mature, and the full transition to BAU is enabled.
Critical actions you should take
Engage PASS
- Commit to a PASS engagement schedule, aligned to the internal development of key elements of your solution build and the broader BAU framework design
- Formalise the engagement approach internally – PASS offers the potential for a different form of interaction with the FCA, but internal stakeholders will need to be comfortable with the prospect of sharing working drafts and conceptual ideas with the regulator
Apply for authorisation
- Ensure appropriate alignment and sequencing of the internal governance path for Targeted Support review and approval and the completion of the formal authorisation application
- Create an agile squad focused on triaging and responding to regulatory input and feedback so further information is developed and submitted seamlessly
- Capture and embed initial commitments to ensure visibility and appropriate governance and oversight in phase two
Deploy day one solution
- Create your 90-day post-deployment plan, including monitoring and assessment of success / risk criteria and detailed understanding of incident escalation paths
- Define your phase two approach and the BAU transition plan in line with your use-case roadmap and ‘change vs. run’ funding
- Consider strategic and delivery alignment with ‘Simplified Advice’ pathway (dependent on the details of FCA Consultation Paper in February 2026)
Challenges you should be aware of
PASS engagement and authorisation will test your agility
You’ll be on a carousel from the point you engage PASS so ensure that you’re effectively organised to manage that feedback channel alongside internal governance and review processes
PASS is likely to be uncomfortable from a cultural perspective
The idea of sharing draft documentation with the FCA is going to alarm some internal stakeholders, ensure that minimum standards of internal review and approval are appropriately defined and calibrated
Post initial launch is likely to be the most challenging period
Reinforce the commitment to the ‘North Star’ and be clear on your objectives in phase two and how you’re going to balance continued build and BAU execution
Our Experts
Targeted Support: What the experts say
Guy Munton, Ellie Simmons and Jo Cordner talk through the key aspects of Targeted Support and explain why it is such an important and exciting development for the financial services sector in this episode of FS in Focus.
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