The Investing and Saving Alliance (TISA) has today warned that without a legislative fix to PECR and clearer non-digital rules, Targeted Support could miss most of the people it is meant to help.
In its responses to the FCA’s consultation and HM Treasury’s policy note on implementing Targeted Support, TISA has urged the government to implement a legislative fix to the Privacy and Electronic Communications Regulations (PECR) to allow Targeted Support to operate on an opt-out basis so providers can contact disengaged and vulnerable customers, rather than only those already-engaged. TISA estimates that under current regulations, firms may only be able to proactively reach as little as a quarter of customers.
TISA is also calling for consistency across all methods of targeted support communication, as it fears the current approach will ultimately lead to a reduction in non-digital Targeted Support offerings. Currently, the FCA’s proposals on how firms should treat new, additional information volunteered by consumers over the phone or in branch could result in firms electing not to offer targeted support ‘offline’, thereby excluding digitally vulnerable consumers. TISA’s proposed approach would preserve Consumer Duty clarity, keep decision-making with the consumer, and ensure Targeted Support is available across every channel.
Carol Knight, Chief Executive of TISA, said:
“TISA has advocated for the Advice Guidance Boundary Review and Targeted Support proposals for years. We are highly supportive of the commitment and constructive approach taken by HMT and the FCA and welcome the momentum to see Targeted Support become a reality. TISA stands ready to help with the next steps, so that Targeted Support can deliver better outcomes for those who need it most.”
Sophie Legrand-Green, Head of Policy at TISA, commented:
“Targeted Support is a smart, consumer-friendly reform, but unless PECR is amended, three out of four consumers could remain out of reach. Our recommendations are pragmatic: enable opt-out outreach so firms can help those who aren’t currently engaging and set clear guardrails so staff can deliver pre-defined support without straying into advice. If we do that, Targeted Support will scale with confidence across every channel; get it wrong and we risk entrenching disengagement.”
TISA has also urged government and regulators to ensure consumers receive consistent help across pensions regardless of whether their scheme is under TPR or the FCA, and across both accumulation and decumulation use cases. From an outcomes perspective, regulatory boundaries should not dictate the level of support available to members who did not choose their workplace provider.
Beyond these priorities, TISA sets out practical changes to make the framework work confidently on the ground. Complaints and redress should mirror the limited scope of Targeted Support so that outcomes are judged against what the service is designed to do, rather than treated as if holistic financial advice had been given.
Finally, TISA recommends disclosure rules focus on what consumers need to understand rather than box-ticking. In particular, firms should not be required to state “remuneration” where Targeted Support is free but cross-subsidised by other services, as this risks confusion and undermining trust; no other service which relies on cross-subsidisation is required to disclose this to users.
