| Page 1 Fair value benchmarking survey 2025
| Page 2 Introduction Introduction Thank you for taking the time to participate in our second Fair Value Benchmarking Survey. We’re pleased to report that 383 firms took part this year, building on the 272 firms who contributed to our inaugural survey. With increased participation, we also gathered more detailed data this time around, having applied key lessons learned from our first survey. We’re committed to continuous improvement and will further refine and clarify next year’s questions to enhance the value and accuracy of the insights. If there is specific information you’d like us to include in future surveys, particularly relating to charging structures or the delivery of fair value, we welcome your feedback. Please note that the findings presented here are based on self-reported data from a wide range of firms with differing propositions. We do not independently verify this information. We’ve chosen to include the range of data alongside the averages, as we believe this provides a view of market variations. We’ve aimed to present the data as clearly and concisely as possible, and have included links to relevant regulatory guidance where appropriate, which we hope you’ll find useful. C oCnotnetnetnst s 1. Executive summary 2. Regulatory profile and firm size 3. Ongoing services and annual suitability reviews 4. Service levels and client segmentation 5. Distribution chain - Charging by location 6. Investments 7. Retirement advice (accumulation) 8. Retirement advice (decumulation) 9. Tax planning 10. Protection 11. Mortgages 12. Equity release 13. Hourly rates 14. Initial meetings and implementation of advice 15. Additional services provided 16. Fair value assessments 3 6 7 9 10 13 18 23 28 33 34 37 40 41 43 44
| Page 3 1. Executive summary Changes to proposition • 39% of firms have adjusted their proposition following their fair value assessment. Annual suitability reviews • 94% of firms in our survey confirmed they are delivering annual suitability reviews on time. - This compares to the FCA’s thematic review, which found that 83% of the 22 largest firms were meeting this requirement. Ongoing services and service levels • 64% of firms indicated they would not offer a refund, partial refund, or service level adjustment when an annual suitability review had not been delivered. • However, 92% of firms reported they have undertaken an exercise to review the suitability of ongoing services for their clients’ and where necessary adjusted service levels for each client based on their needs. • 84% of firms offer up to three service levels. • A third of firms provide exactly three service levels. Total initial and ongoing charge (including the distribution chain) • The survey indicates a 0.07% decrease in overall ongoing charges across the distribution chain. • The average total ongoing charge in 2024 was 1.52% decreasing to 1.45% in 2025. • The average initial charge in 2025 is 1.87%. • Consumer Duty regulations continue to shape these trends, ensuring services deliver fair value to consumers. 1. Executive summary Key findings from the data provided - Fair value benchmarking survey
| Page 4 Investments • Average initial advice charge: 1.74%. Ongoing advice: 0.79%. • Charging Methods: The most common method continues to be % AUM (Assets Under Management). Retirement accumulation • Average initial advice charge: 1.50%. Ongoing fee: 1.05%. - The ongoing charge is slightly above the standard 1% which could be reflective of the additional work required in later retirement planning. • Charging methods: The most common is % of AUM, followed closely by tiered % AUM for both initial and ongoing advice. Retirement decumulation • Average initial advice charge: 1.65%. Ongoing fee: 0.84%. • Charging methods: The most common is tiered % AUM for both initial and ongoing advice. • Tiered structures help manage value disparity, particularly as AUM declines in the decumulation phase of retirement. Tax planning • Average initial advice charge: 1.61%. Ongoing fee: 0.82%. • Charging methods: - Initial tax planning advice is often provided without a separate charge. - Ongoing tax planning is typically charged as a % of AUM. • Decency limits: Most firms do not impose decency limits on tax planning fees. Mortgages • Average fixed charge, excluding procuration fee / commission: £729.53. • Charging methods: - A combination of flat fixed fees and commission / procuration fees are the most common charging method. Advice types and charging structures 1. Executive summary
| Page 5 Protection • The most common decency limits for protection advice were: - Minimum charge: £500. - Maximum charge: £10,000. • Charging method: - Commission remains the most common approach. Equity release • The FCA states that the typical advice fee for Lifetime Mortgages is £1,500 for loans between £200,000 – £300,000. - Our survey shows a slightly higher average charge of £1,626.63. • Charging method: - Most firms use a flat fixed fee, combined with commission or procuration fees based on loan percentage. Other charging methods - average hourly rates (all advice types) • Administrators: £86.57. • Paraplanners: £136.94. • Advisers: £248.82. Initial meetings (all advice types) • 80% of firms offer an initial meeting at their own cost, this is usually following an informed conversation to qualify a lead. 1. Executive summary
| Page 6 2. Regulatory profile and firm size Throughout this report, we’ve analysed the data by firm size and geographic location. As the type and number of firms supplying data can influence the results, we have indicated the number of participant firms in the relevant sections to provide context for the analysis. 1.1. Respondents regulatory profile and firm size Firm type No. of firms All firms 383 Appointed representative 12 Article 3 exempt 330 Authorised professional firm 1 MIFIDPRU 38 Mortgage and protection 2 Firm size No. of firms All firms 383 Large firm (over 25 advisers) 20 Medium firm (6 - 25 advisers) 128 Small firm (2 - 5 advisers) 170 Single adviser firm 65 2 Respondents profile
| Page 7 3. Ongoing services and annual suitability reviews 3. Ongoing services and annual suitability reviews 3.1. What percentage of annual suitability reviews are being delivered on time and in line with your service proposition? 3.2. Where an annual suitability review hasn’t been delivered, are you offering the client a refund/ part refund or a change to their service level? The delivery of annual suitability reviews continues to be a key area of focus. To explore this further, we introduced three high-level questions to gather supporting data. This year, 94% of firms reported that they are delivering annual suitability reviews on time, an improvement from 88% in last year’s survey (see Figure 3.1). The survey results suggest that smaller firms are more likely to offer a client refund, partial refund, or an adjustment to their service level if a review has not been completed (see Figure 3.2 and 3.3). Average percentage All participants 94% Average by firm size: Large firms (over 25 advisers) 92% Medium firms (6 to 25 advisers) 93% Small firms (2 to 5 advisers) 96% Single adviser firms 94% No Yes All participants 64% 36% Average by firm size: Large firms (over 25 advisers) 86% 14% Medium firms (6 to 25 advisers) 67% 33% Small firms (2 to 5 advisers) 60% 40% Single adviser firms 64% 36%
| Page 8 3. Ongoing services and annual suitability reviews 3.3. Have you reviewed the suitability of ongoing services to clients and moved clients accordingly? Related reading Providing ‘fair value’ to consumers receiving ongoing services includes clearly disclosing the nature and timing of services, effective systems for suitability reviews, and policies for dealing with clients who aren’t actively engaging. In February 2024, the FCA published a review of ongoing financial advice services. All firms should read the FCA’s findings and take the necessary action to make sure clients are getting the services they are paying for. • threesixty client portal guidance FCA’s review of ongoing financial advice services - April 2025 • threesixty Round Up article Ending client relationships - Are your disengagement processes in order? - September 2024 • FCA publication Ongoing financial advice services - February 2025 No Yes All participants 8% 92% Average by firm size: Large firms (over 25 advisers) - 100% Medium firms (6 to 25 advisers) 5% 95% Small firms (2 to 5 advisers) 9% 91% Single adviser firms 9% 91%
| Page 9 4. Service levels and client segmentation Most firms continue to offer 1 to 3 service levels, which remains the most common approach (see Figure 4.1). Many of these structures have been in place since the introduction of the Retail Distribution Review (RDR) in 2013, with some still using the original consultancy-style labelling of Bronze, Silver, and Gold. In contrast, some firms have adopted a more flexible, menu-based service proposition, where the offering is adapted to the client’s individual needs. This can include variations in review frequency, the complexity of circumstances, and additional one-off services. While one to three distinct service levels remain the norm, we are seeing a growing number of firms tailoring their services further, for example to differentiate services for different client life stages and expect this trend to continue. In our previous survey, only 9% of firms offered more than four service levels, this has increased to 16%. 4. Service levels and client segmentation 4.1. Number of core service levels per firm 1 - 3 4 - 6 7 - 9 10 + All participants 84% 13% 1% 2% Average by firm size: Large firms (over 25 advisers) 72% 17% 6% 5% Medium firms (6 to 25 advisers) 84% 15% - 1% Small firms (2 to 5 advisers) 85% 10% 2% 3% Single adviser firms 83% 7% - - Related reading Client segmentation (dividing your client base into smaller groups of individuals with similar characteristics or needs) can help firms demonstrate that the price charged for services reflects the services your clients receive. By understanding client needs and offering appropriately targeted services firms should be able to better justify the cost of their services and demonstrate that clients are receiving fair value. • threesixty client portal guidance Client segmentation - January 2025 • threesixty Round Up article Why getting your target market assessment procedures in order is essential - February 2025
| Page 10 5. Distribution chain - Charging by location 5. Distribution chain and location In our first survey, 52% of participants indicated they planned to make changes to their fee structures, largely anticipating increases due to competitor benchmarking and rising operational costs. However, the results from this year suggest that reductions elsewhere in the distribution chain may be influencing overall fee trends. Our latest data shows a 0.07% decrease in the average ongoing charges across the distribution chain compared to last year (see Figure 5.1). That said, regional differences remain notable: • Wales bucked the national trend, with average fees rising by 0.15%. The average ongoing charge in Wales remains 0.16% below the national average. • South West England and Northern Ireland recorded the largest fee reductions, both at 0.27%. Average charge 2024 Average charge 2025 % change All participants 1.52% 1.45% - 0.07% Average by region: Scotland 1.57% 1.38% - 0.19% Northern Ireland 1.42% 1.15% - 0.27% North East England 1.51% 1.33% - 0.18% North West England 1.60% 1.48% - 0.12% Wales 1.14% 1.29% 0.15% Central England 1.57% 1.45% - 0.12% East of England 1.63% 1.62% - 0.01% Greater London 1.56% 1.57% 0.01% South East England 1.59% 1.41% - 0.18% South West England 1.63% 1.36% - 0.27% 5.1. Movement in average total charge including ongoing advice (UK) Min: 0.15% Max: 2.8% Average total charge including ongoing advice (2025) Avg: 1.45%
| Page 11 5. Distribution chain and location 5.2. Average initial advice fees and total ongoing fees including advice Min: 0.2% Max: 8% Average initial advice fees Avg: 1.87% Min: 0.15% Max: 2.8% Total ongoing fees (including advice, product, platform and fund management fees) Avg:1.45% Average initial fee clients pay Average ongoing fee clients pay All participants 1.87% 1.45% Average by region: Scotland 1.93% 1.38% Northern Ireland 1.25% 1.15% North East England 1.60% 1.33% North West England 1.89% 1.48% Wales 2.02% 1.29% Central England 2.08% 1.45% East of England 2.45% 1.62% Greater London 1.92% 1.57% South East England 1.53% 1.41% South West England 1.58% 1.36%
| Page 12 Related reading Ensuring fair value throughout the distribution chain is a core principle under the Consumer Duty. This means manufacturers, distributors, and all parties involved must work together to assess and ensure fair value at each stage of the chain. • threesixty client portal guidance Meeting your price and value obligations as a distributor - January 2025 • threesixty Round Up article Do you need to update your product governance arrangements? - October 2024 • NextWealth Financial Advice Business Benchmarks Going for growth | Issue 6 - October 2024
| Page 13 6. Investments Of the 383 firms that participated in the survey, 363 confirmed they provide investment advice. The average charges reported were: • Initial advice: 1.74% • Ongoing advice: 0.79% The average fee increased from £1,328.78 in 2024 to £1,421.33 in 2025. The most common method for ongoing charging remains percentage of Assets Under Management (% AUM), both tiered and non-tiered. Our data suggests a growing trend towards tiered %AUM charging structures, often combined with minimum and maximum fees. These approaches are increasingly seen as effective in addressing cross-subsidy concerns and demonstrating fairness, particularly for clients with significantly different investment values. 6. Investments Advice 2025 Initial investment advice 1.74% Ongoing investment advice 0.79% 6. 1. Average charge for investment advice (%) Min: 0.5% Max: 5% Average charge for initial investment advice Avg: 1.74% Min: 0.3% Max: 7.5% Average charge for ongoing investment advice Avg: 0.79%
| Page 14 6.2. Minimum and maximum fees for investment advice 6. Investments Average of minimum initial Average of minimum ongoing Average of maximum initial Average of maximum ongoing All participants £1,416.47 £1,421.33 £12,718.32 £17,613.70 Average by firm size: Large firms (over 25 advisers) £1,350.00 £1,230.56 £14,166.67 £13,333.33 Medium firms (6 to 25 advisers) £1,376.04 £1,198.27 £16,247.50 £24,808.82 Small firms (2 to 5 advisers) £1,461.75 £1,682.79 £11,384.43 £17,116.52 Single adviser firms £1,371.29 £1,176.95 £10,247.22 £11,840.00 Min: £100 Max: £6000 Average of minimum initial Avg: £1,416 Min: £120 Max: £15,000 Average of minimum ongoing Avg: £1,421 Min: £500 Max: £50,000 Average of maxiumum initial Avg: £12,718 Min: £3,000 Max: £85,000 Average of maximum ongoing Avg: £17,614
| Page 15 2025 fees Initial fee Ongoing fee 0 20 40 60 80 100 120 140 160 180 200 0 2,000 4,000 6,000 8,000 10,000 12,000 14,000 16,000 18,000 20,000 £1,421.33 £1,416.47 2024 fees Average minimum fees (£) for investment advice £1,328.78 £1,172.39 2025 fees Initial fee Ongoing fee 0 20 40 60 80 100 120 140 160 180 200 0 2,000 4,000 6,000 8,000 10,000 12,000 14,000 16,000 18,000 20,000 £12,718.32 17,613.70 2024 fees Average maximum fees (£) for investment advice £11,622.77 £14,615.68 6.3. Minimum and maximum fees for investment advice
| Page 16 Charging method Responses % of AUM 47% % of AUM (tiered) 35% Flat fixed fee 7% Hourly fee 2% Tiered fees 0% N/A (no fee) 9% 6.4. Charging method for initial investment advice 6. Investments Charging method Responses % of AUM 24% % of AUM (tiered) 36% Flat or fixed fee 28% Hourly fee 12% Tiered fees 0% N/A 0% 2025 2024
| Page 17 6. Investments Charging method Responses % of AUM 60% % of AUM (tiered) 37% Flat fixed fee 1% Hourly fee 1% Tiered fees 1% Retainer fees 0% N/A (no fee) 0% 6.5. Charging method for ongoing investment advice Charging method Responses % of AUM 49% % of AUM (tiered) 28% Flat or fixed fee 10% Hourly fee 9% Tiered fees 0% Retainer fees 4% N/A 0% 2025 2024 Related reading The Consumer Duty requires firms to charge reasonably and justify their prices, ensuring value for money for clients. • threesixty client portal guidance Setting fair charges - January 2025
| Page 18 7. Retirement advice (accumulation) 7. Retirement advice (accumulation) Of the 383 firms surveyed, 330 firms reported providing advice in relation to retirement accumulation. Average charges (see Figure 7.1) • Initial advice fee: 1.51% • Ongoing advice fee: 1.05% Decency limits (see Figure 7.2) The minimum and maximum charges reported are broadly consistent across both the accumulation and decumulation phases - see 8. Retirement advice (decumulation). Tiered % of AUM charging models, particularly those with defined minimum and maximum fees, continue to be effective in addressing cross-subsidy concerns and ensuring fairness across clients with varying investment levels. Charging methods (see Figure 7.3 and 7.4) The most commonly used method remains a flat % of AUM, closely followed by tiered % AUM structures for both initial and ongoing advice. 7.1. Average charge for initial and ongoing retirement and pension planning advice (accumulation) Average charge for initial advice Average charge for ongoing advice All participants 1.51% 1.05% Average by firm size: Large firms (over 25 advisers) 1.83% 0.92% Medium firms (6 to 25 advisers) 1.49% 0.81% Small firms (2 to 5 advisers) 1.48% 1.07% Single adviser firms 1.51% 1.43%
| Page 19 7. Retirement advice (accumulation) 7.2. Minimum and maximum fees for Retirement planning advice (accumulation) Average of minimum initial Average of minimum ongoing Average of maximum initial Average of maximum ongoing All participants £1,470.72 £1,308.48 £12,135.33 £16,176.71 Average by firm size: Large firms (over 25 advisers) £1,360.00 £1,009.38 £16,000.00 £13,333.33 Medium firms (6 to 25 advisers) £1,399.64 £1,248.33 £13,894.12 £18,950.00 Small firms (2 to 5 advisers) £1,554.24 £1,420.88 £11,410.82 £16,916.82 Single adviser firms £1,355.37 £1,160.89 £10,096.67 £11,435.71 Average of minimum initial Min: £100 Max: £37,500 Average of minimum ongoing Avg: £1,308 Min: £500 Max: £50,000 Average of maxiumum initial Avg: £12,135 Min: £3,000 Max: £85,000 Average of maximum ongoing Avg: £16,177 Min: £100 Max: £15,000 Avg: £1,471
| Page 20 2025 fees Initial fee Ongoing fee 0 20 40 60 80 100 120 140 160 180 200 0 2,000 4,000 6,000 8,000 10,000 12,000 14,000 16,000 18,000 20,000 £1,470.72 £1,308.48 Average minimum fees (£) for retirement advice (accumulation) 2025 fees Initial fee Ongoing fee 0 20 40 60 80 100 120 140 160 180 200 0 2,000 4,000 6,000 8,000 10,000 12,000 14,000 16,000 18,000 20,000 £12,135.33 £16,176.71 Average maximum fees (£) for retirement advice (accumulation) 7.3. Minimum and maximum fees for Retirement planning advice (accumulation)
| Page 21 7. Retirement advice (accumulation) Charging method Responses % of AUM 44% % of AUM (tiered) 32% Flat fixed fee 4% Hourly fee 1% Tiered fees 0% Retainer fees 0% N/A (no fee) 19% 7.4. Charging method for initial retirement and pension planning advice (accumulation) Charging method Responses % of AUM 22% % of AUM (tiered) 29% Flat or fixed fee 43% Hourly fee 6% Tiered fees 0% Retainer fees 0% N/A 0% 2025 2024
| Page 22 7. Retirement advice (accumulation) Charging method Responses % of AUM 59% % of AUM (tiered) 37% Flat fixed fee 2% Hourly fee 2% Tiered fees 0% Retainer fees 0% N/A (no fee) 0% 7.5. Charging method for ongoing retirement and pension planning advice (accumulation) Charging method Responses % of AUM 46% % of AUM (tiered) 28% Flat or fixed fee 19% Hourly fee 5% Tiered fees 0% Retainer fees 2% N/A 0% 2025 2024 Related reading Advising on investing and saving money to build up a retirement fund is a core activity for many threesixty clients. • threesixty client portal guidance Planning for retirement (accumulation) - April 2025
| Page 23 8. Retirement advice (decumulation) 8. Retirement advice (decumulation) Of the 383 firms surveyed, 325 firms provided advice on retirement decumulation. 8.1. Average charge for initial and ongoing retirement and pension planning advice (decumulation) Average charge for initial advice Average charge for ongoing advice All participants 1.65% 0.84% Average by firm size: Large firms (over 25 advisers) 1.89% 0.93% Medium firms (6 to 25 advisers) 1.73% 0.78% Small firms (2 to 5 advisers) 1.58% 0.85% Single adviser firms 1.62% 0.90% Min: 0.1% Max: 5.8% Average charge for initial retirement advice (decumulation) Avg: 1.54% Min: 0.2% Max: 5% Average charge for ongoing retirement advice (decumulation) Avg: 0.84%
| Page 24 8. Retirement advice (decumulation) 8.2. Minimum and maximum fees for retirement planning advice (decumulation) Average of minimum initial Average of minimum ongoing Average of maximum initial Average of maximum ongoing All participants £1,521.44 £1,496.74 £13,187.72 £15,675.07 Average by firm size: Large firms (over 25 advisers) £1,585.00 £1,228.13 £18,000.00 £16,666.67 Medium firms (6 to 25 advisers) £1,495.66 £1,353.89 £12,972.73 £15,896.88 Small firms (2 to 5 advisers) £1,574.71 £1,676.29 £13,957.31 £17,238.21 Single adviser firms £1,360.21 £1,326.40 £8,034.62 £10,123.08 Average of minimum initial Min: £200 Max: £15,000 Average of minimum ongoing Avg: £1,497 Min: £1,500 Max: £85,000 Average of maximum ongoing Avg: £15,675 Min: £100 Max: £6,000 Avg: £1,521 Min: £500 Max: £150,000 Average of maximum initial Avg: £13,188
| Page 25 2025 fees Initial fee Ongoing fee 0 20 40 60 80 100 120 140 160 180 200 0 2,000 4,000 6,000 8,000 10,000 12,000 14,000 16,000 18,000 20,000 £1,521.44 £1,496.74 Average minimum fees (£) for retirement advice (decumulation) 2025 fees Initial fee Ongoing fee 0 20 40 60 80 100 120 140 160 180 200 0 2,000 4,000 6,000 8,000 10,000 12,000 14,000 16,000 18,000 20,000 £13,187.72 £15,675.07 Average maximum fees (£) for retirement advice (decumulation) 8.3. Minimum and maximum fees for retirement planning advice (decumulation)
| Page 26 8. Retirement advice (decumulation) Charging method Responses % of AUM 42% % of AUM (tiered) 31% Flat fixed fee 5% Hourly fee 1% Tiered fees 0% Retainer fees 0% N/A (no fee) 21% 8.4. Charging method for initial Retirement planning advice (decumulation) Charging method Responses % of AUM 23% % of AUM (tiered) 27% Flat or fixed fee 42% Hourly fee 8% Tiered fees 0% Retainer fees 0% N/A 0% 2025 2024
| Page 27 8. Retirement advice (decumulation) Charging method Responses % of AUM 51% % of AUM (tiered) 33% Flat fixed fee 0% Hourly fee 0% Tiered fees 0% Retainer fees 0% N/A (no fee) 16% 8.5. Charging method for ongoing retirement planning advice (decumulation) Charging method Responses % of AUM 46% % of AUM (tiered) 28% Flat or fixed fee 20% Hourly fee 5% Tiered fees 0% Retainer fees 1% N/A 0% 2025 2024 Related reading Advising on investing and saving money to build up a retirement fund is a core activity for many threesixty clients. • threesixty client portal guidance Accessing pension savings (decumulation) - April 2025 Retirement income advice review - April 2024 • FCA publication Thematic review of Retirement Income Advice - March 2024
| Page 28 9. Tax planning 9. Tax planning Of the 383 firms that participated in the survey, 230 confirmed they provide tax planning. • Decency limits (see Figure 9.2) The majority of partcipants did not have decency limits for initial and ongoing tax planning advice. Where decency limits are used: - The average maximum for initial advice is £10,884.86. - The average maximum for ongoing advice is £17,268.55. • Charging methods (see Figure 9.3 and 9.4) Initial tax planning advice is often provided at no additional charge. Whilst the most common method for ongoing tax planning advice is a % of Assets Under Management (AUM), a flat fixed fee is becoming increasingly popular. 9.1. Average business charge for initial and ongoing tax planning advice Average charge for initial advice Average charge for ongoing advice All participants 1.61% 0.82% Average by firm size: Large firms (over 25 advisers) 2.17% 0.90% Medium firms (6 to 25 advisers) 1.55% 0.77% Small firms (2 to 5 advisers) 1.54% 0.82% Single adviser firms 1.71% 0.91% Min: 0.35% Max: 4% Average charge for initial tax planning advice Avg: 1.61% Min: 0.2% Max: 2.5% Average charge for ongoing tax planning advice Avg: 0.82%
| Page 29 9. Tax planning 9.2. Minimum and/or maximum fees for tax planning advice Average of minimum initial Average of minimum ongoing Average of maximum initial Average of maximum ongoing All participants £1,647.52 £1,356.98 £10,884.86 £17,268.55 Average by firm size: Large firms (over 25 advisers) £1,625.00 £865.00 £20,000.00 £20,000.00 Medium firms (6 to 25 advisers) £1,320.65 £1,102.27 £11,619.05 £24,428.57 Small firms (2 to 5 advisers) £1,859.87 £1,580.38 £10,456.90 £16,343.10 Single adviser firms £1,388.89 £1,540.00 £7,416.67 £10,400.00 Average of minimum initial Min: £125 Max: £6,000 Average of minimum ongoing Avg: £1,357 Min: £750 Max: £85,000 Average of maximum ongoing Avg: £17,269 Min: £125 Max: £15,000 Avg: £1,648 Min: £500 Max: £36,000 Average of maximum initial Avg: £10,885
| Page 30 2025 fees Initial fee Ongoing fee 0 20 40 60 80 100 120 140 160 180 200 0 2,000 4,000 6,000 8,000 10,000 12,000 14,000 16,000 18,000 20,000 £1,647.52 £1,356.98 Average minimum fees (£) for tax planning advice 2025 fees Initial fee Ongoing fee 0 20 40 60 80 100 120 140 160 180 200 0 2,000 4,000 6,000 8,000 10,000 12,000 14,000 16,000 18,000 20,000 £10,884.86 £17,268.55 Average maximum fees (£) for tax planning advice 9.3. Minimum and/or maximum fees for tax planning advice
| Page 31 9. Tax planning Charging method Responses % of AUM 38% % of AUM (tiered) 18% Flat fixed fee 8% Hourly fee 2% Tiered fees 0% Retainer fees 0% N/A (no additional fee) 34% 9.4. Charging method for initial tax planning advice Charging method Responses % of AUM 9% % of AUM (tiered) 15% Flat or fixed fee 23% Hourly fee 43% Tiered fees 7% Retainer fees 3% N/A 0% 2025 2024
| Page 32 9. Tax planning Charging method Responses % of AUM 42% % of AUM (tiered) 17% Flat fixed fee 5% Hourly fee 1% Tiered fees 0% Retainer fees 1% N/A (no additional fee) 34% 9.5. Charging method for ongoing tax planning advice Charging method Responses % of AUM 22% % of AUM (tiered) 15% Flat or fixed fee 37% Hourly fee 26% Tiered fees 0% Retainer fees 0% N/A 0% 2025 2024 Related reading Changes announced in the October 2024 Budget could affect clients’ investment strategies, estate planning, and retirement savings. • threesixty client portal guidance Autumn Statement 2024 - October 2024
| Page 33 10. Protection 10. Protection Charging method Responses Commission based 77% Flat fixed fee 9% Hourly fee 1% N/A (no fee) 13% 10.1. Most used charging method for protection advice 2025 Of the 383 firms that participated in the survey, 315 provided protection advice. 248 participant firms recorded average commission size with a range from £100 to £10,000. Of those 37% are below £1,000, 47% are between £1,000 and £2,000 and 16% in excess of £2,000. 34% of participants have a minimum charge for protection, with £500 the most common. 29% of participants have a maximum charge for protection, with a range of £500 to £50,000, with £10,000 the most common. Related reading In April 2025 the FCA launched a market study into the distribution of pure protection products. Areas the FCA will be looking at include whether products provide fair value, and whether commission structures encourage advisers to suggest unnecessary switching. • threesixty client portal guidance FCA launches market study into distribution of pure protection products - April 2025 • FCA publication Market study into the distribution of pure protection products to retail customers - terms of reference - March 2025
| Page 34 11. Mortgages 11. Mortgages Of the 383 firms surveyed, 122 firms provided mortgage advice: • Average advice fee charges The average charge is £729.53, excluding procuration fee. • Decency limits (see Figure 11.1) Out of the 122 firms surveyed, 104 firms do not apply a decency limit. There has been a decrease in both maximum and minimum charges for mortgage advice, however not all paricipants completed the maximum charges questions. - Maximum charge dropped from £2,884.30 to £1,303.50. - Minimum charge decreased from £600.78 to £549.59. • Firm size and charging (see Figure 11.1) Larger firms tend to charge more than smaller firms for mortgage advice. • Charging methods (see Figure 11.2) The most common approach is a flat fixed fee, along with commission or procuration fees based on a percentage of the loan amount.
| Page 35 11. Mortgages 11.1. Minimum and maximum fees for mortgage advice 2025 fees Minimum charge Maximum charge 0 50 100 150 200 250 300 £549.59 £1,303.50 2024 fees Average minimum fees (£) for mortgage advice £600.78 0 500 1000 1,500 2,000 2,500 3,000 £2,884.30 Minimum charge Maximum charge All participants £549.59 £1,303.50 Average by firm size: Large firms (over 25 advisers) £1,035.00 - Medium firms (6 to 25 advisers) £484.67 795.00 Small firms (2 to 5 advisers) £495.33 £1,740.50 Single adviser firms £350.00 £498.33 Min: £145 Max: £1,750 Average minimum charge for mortgage advice Avg: £550 Min: £295 Max: £10,000 Average maximum charge for mortgage advice Avg: £1,304
| Page 36 11. Mortgages Charging method Responses Commission based 26% Flat fixed fee 7% Hourly fee 0% Flat fixed fee as well as commission / procuration fee (% loan amount) 51% N/A (no fee) 2% 11.2. Most used charging method for mortgage advice Charging method Responses Commission based 39% Flat or fixed fee 58% Hourly fee 3% N/A 0% 2025 2024 Related reading The regulator’s key priority, over the next two years, will be on how firms are embedding the Consumer Duty in the mortgage advice sector. On fair value, the FCA has found evidence of both good and poor practice when reviewing firms’ fair value assessments. • threesixty client portal guidance FCA outlines supervisory strategy for mortgage intermediaries for next two years - February 2025 • FCA publication FCA strategy for mortgage intermediaries - January 2025
| Page 37 12. Equity release Of the 383 firms surveyed, 94 firms provided advice on equity release and lifetime mortgages: • Average charges The FCA indicates that the average advice fee for lifetime mortgages is currently £1,500 for recommendations totalling £200,000 to £300,000, suggesting a standardised approach to pricing. The survey results show a slightly higher average charge of £1,626.63. • Charging range (see Figure 12.1) There has been an increase in both maximum and minimum charges for equity release advice: - Maximum charge increased from £3,565.44 in 2024 to £5,083.38 in 2025. - Minimum charge rose from £1,152.13 in 2024 to £1,220.32 in 2025. • Firm size and charging (see Figure 12.1) It is observed that medium sized firms appear to charge slightly less than small and large firms for equity release advice. Firms should ensure they should provide clear information on how their fees are determined and remain transparent to demonstrate fair value. • Charging methods (see Figure 12.2) The most common approach is a flat fixed fee, combined with commission or procuration fees based on a percentage of the loan amount. 12. Equity release
| Page 38 12. Equity release 2025 fees Minimum charge Maximum charge 0 100 200 300 400 500 600 £1,220.32 £5,083.38 2024 fees Average minimum fees (£) for equity release advice £1,152.13 £3,565.44 0 1,000 2,000 3,000 4,000 5,000 6,000 12.1. Minimum and maximum fees for equity release advice Average minimum charge Average maximum charge All participants £1,220.32 £5,083.38 Average by firm size: Large firms (over 25 advisers) £1,419.00 £5,600.00 Medium firms (6 to 25 advisers) £902.69 £3,353.64 Small firms (2 to 5 advisers) £1,346.43 £6,016.33 Single adviser firms £1,281.25 £5,750.00 Min: £200 Max: £3,250 Average mnimum charge for equity release advice Avg: £1,220 Min: £495 Max: £15,000 Average maximum charge for equity release advice Avg: £5,083
| Page 39 12. Equity release Charging method Responses Commission based 22% Flat fixed fee 10% Hourly fee 0% Flat fixed fee as well as commission / procuration fee (% loan amount) 67% N/A (no fee) 1% 12.2. Most used charging method for equity release advice Charging method Responses Commission based 16% Flat or fixed fee 75% Hourly fee 9% N/A 0% 2025 2024
| Page 40 13. Hourly rates 13. Hourly rates Of those firms participating in the survey, large firms charge more than small firms for advice chared at an hourly rate (see Figure 13.1). 13.1. Average hourly charge (where offered) Administrators (hourly charge) Paraplanners (hourly charge) Advisers (hourly charge) All participants £86.57 £136.94 £248.82 Average by firm size: Large firms (over 25 advisers) £114.29 £200.00 £349.63 Medium firms (6 to 25 advisers) £93.57 £142.73 £244.36 Small firms (2 to 5 advisers) £79.62 £135.51 £238.79 Single adviser firms £87.88 £112.48 £255.97 Average hourly charge - Administrators Min: £25 Max: £350 Average hourly charge - Paraplanners Avg: £137 Min: £20 Max: £350 Avg: £87 Min:£50 Max: £600 Average hourly charge - Advisers Avg: £249
| Page 41 14. Initial meetings and implementation of advice Approximately 80% of financial advisers provide an initial consultation at the firm’s expense, allowing potential clients to assess whether their services meet their needs and to understand the associated costs. Depending on the services requested and the duration of the engagement, advisers may offer a range of charging options. Clients often move from receiving initial advice to the implementation of the recommended strategies after reviewing the adviser’s report. It is essential at this point that advisers communicate all fees clearly to clients to avoid any unexpected costs. While many advisers typically charge a percentage of the investment for setup and ongoing services, some may offer a combination of fixed fees and percentage-based charges. 14. Initial meetings and implementation of advice
| Page 42 14.1. Provision of initial meetings at own cost 14. Initial meetings and implementation of advice No Yes All participants 20% 80% Average by firm size: Large firms (over 25 advisers) 30% 70% Medium firms (6 to 25 advisers) 20% 80% Small firms (2 to 5 advisers) 16% 84% Single adviser firms 26% 74% Yes No
| Page 43 15. Additional services provided 15.1. What services are included as standard? Access to adviser outside of review meetings 93.4% Access to client team for ad-hoc queries 92.1% Annual suitability assessment and report 91.2% Cashflow modelling 68.2% Face to face meetings at least annually 80.3% Financial planning 83.6% Implementation of agreed changes 90.2% Liaising with other professionals on behalf of the client 77.4% Newsletters / other client communications 69.2% Online virtual / telephone meetings 92.5% Regular reporting of investment performance 73.8% Retirement and estate planning 77.1% Review of asset allocation and how assets are invested 87.9% Review of financial goals and objectives 91.8% Tax planning 65.9% Up to date valuations 88.9% 15. Additional services provided
| Page 44 No Yes All participants 61% 39% Average by firm size: Large firms (over 25 advisers) 59% 41% Medium firms (6 to 25 advisers) 52% 48% Small firms (2 to 5 advisers) 64% 36% Single adviser firms 71% 29% 16. Fair value assessments Currently 39% of all firms who took part in the survey have made changes to their proposition since their initial fair-value assessment. We expect this number to increase as firms prepare for their Governing Body Consumer Duty Annual Assessment. 16. Fair value assessments 15.1. Made or planning changes since firm’s initial fair value assessment Yes No
| Page 45 Related reading Under the Consumer Duty, firms must conduct fair value assessments. Firms must be able to clearly explain the value their services provide, and why they charge what they do. While most firms can articulate this, it’s often not well-documented. In October 2024, to FCA shared a ‘good and poor practice update’ on firms’ fair value assessments. • threesixty client portal guidance Charging for services and demonstrating fair value - January 2025 Consumer Duty – FCA publishes good and poor practice update on the price and value outcome - October 2024 • FCA publication Price and Value Outcome: Good and Poor Practice update - October 2024 16. Fair value assessments
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