TISA urges action to boost Targeted Support for more consumers

The Investing and Saving Alliance (TISA) has raised concerns that new Targeted Support proposals could fail to reach most intended consumers unless legislation and regulatory guidance are updated.

The organisation has responded to the Financial Conduct Authority's (FCA) consultation and the Treasury's policy note on implementing Targeted Support, urging government action to amend the Privacy and Electronic Communications Regulations (PECR). According to TISA, the current PECR rules limit the ability of firms to proactively contact disengaged and vulnerable customers, restricting outreach efforts to those already actively engaging with their providers.

TISA estimates that, under the existing framework, only around a quarter of customers could be reached proactively by firms offering Targeted Support. Its proposed legislative fix would enable Targeted Support to operate on an opt-out basis, thereby potentially increasing access for those who might benefit most.

Legislative and regulatory hurdles

In its communications to policymakers, TISA has emphasised the importance of consistency in applying Targeted Support across both digital and non-digital channels. Concerns have been raised that current FCA proposals relating to how firms handle new information provided over the phone or in branch could result in a decrease in non-digital Targeted Support, potentially excluding customers who are less comfortable with online communication.

TISA is advocating for an approach that would clarify the rules for all communication channels. The organisation warns that without such clarity, firms may choose not to offer 'offline' Targeted Support, thereby disadvantaging digitally vulnerable consumers. TISA argues that its recommended approach would preserve clarity under the Consumer Duty regime, allow customers to retain decision-making power, and ensure Targeted Support is widely available.

Carol Knight, Chief Executive of TISA, underscored the group's longstanding commitment to these policy discussions and its willingness to support the implementation process.

"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, expanded on these points, warning that the majority of consumers might remain out of reach unless amendments are made to the legislative framework.

"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."

Pensions and regulatory alignment

TISA has called on the government and regulators to ensure consumers receive consistent help with pensions, regardless of oversight by the Pensions Regulator (TPR) or the FCA, and to provide continuity of support across different stages of pension saving and drawdown. The organisation notes that regulatory differences should not affect the support available to workplace pension scheme members.

According to TISA, from an outcomes perspective, the framework for support should be neutral with respect to regulatory boundaries, ensuring that members who did not actively choose their provider receive fair treatment.

Other recommendations

Alongside legislative changes, TISA has proposed practical measures to support the implementation of the Targeted Support framework. This includes ensuring complaints and redress mechanisms are aligned with the limited scope of the Targeted Support service. The group suggests that outcomes should be assessed according to what the service is designed to achieve, rather than being held to the standards of full financial advice.

TISA also recommends that disclosure rules focus on what information is essential for consumers to understand the service. The organisation has cautioned explicitly against requiring firms to disclose details about "remuneration" where Targeted Support is free but subsidised by other services, arguing that such requirements risk confusing consumers and eroding trust. TISA notes that similar services relying on cross-subsidisation do not have this disclosure obligation.