Jurisdiction(s):
United Kingdom

UK Financial Services Targeted Support Regime: Direct Marketing (PECR/UK GDPR) Reforms, Consumer Duty Alignment, and Segmentation and Litigation Risks

Published on: 14 July 2025

Published by a Law360 reporter

Legal News

Article summary

Targeted support regime set to launch in 2026

The targeted support regime, due in 2026, will permit banks, financial advisers and others to recommend products to cohorts of similar customers, described as segments. Businesses employ segmentation to cluster consumers and deliver targeted support, narrowing suggestions to fit attributes commonly shared within each group. Yet the main barrier is the danger that firms could breach current rules by issuing marketing communications to investors. Regulatory lawyers are relying on the government to publish a policy paper on Tuesday 15 July 2025 setting out changes to financial services rules to make targeted support proposals workable. While commentators are generally positive about governmental backing for legal adjustments, they also note uncertainty about how the wider approach aligns with existing consumer protection measures under the FCA’s Consumer Duty. ‘There is significant tension between what the FCA is suggesting firms could do in the context of the targeted support and what those same firms are prohibited from doing under the direct marketing rules,’ said Michelle Quinn, Partner at Grosvenor Law. ‘Ultimately, if firms don't feel confident offering targeted support, the whole regime risks falling flat, as few will take the chance of breaching marketing’...

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