Log in or register
Share on LinkedInShare on LinkedIn

ARTICLE · 05 JANUARY 2026

Cheat Sheet—FCA's New Targeted Support Regime—Applying For The New Permission

A&O Shearman
A&O Shearman
Contributor

A&O Shearman

Introducing A&O Shearman Unparalleled global depth for a changing world. Today more than ever,...

View firm profile
Explore more from A&O Shearman

The FCA has issued near final rules on its new targeted support regime to address the UK "advice gap" and help advance its new "regulation for growth" agenda.

United StatesConsumer Protection
Tamara Cizeika
Tamara Cizeika
Author LinkedIn connections

What do firms have to do?

  • For firms that wish to begin to provide targeted support, they need to apply for permission to enable them to conduct this
  • To support their application, they need to establish appropriate systems and controls and risk management, and design their approach to compliance They need to update

their systems to ensure they are keeping appropriate records in respect of the targeted support services they provide.

They need to create new policies and procedures, train staff as relevant on the new requirements, and create appropriate marketing plans, consumer facing materials and a target operating model.

  • Firms that propose to charge for targeted support need to be able to demonstrate it provides fair

We operate a free-to-view policy, asking only that you register in order to read all of our content. Please login or register to view the rest of this article.

Register for freeORLog in

The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.

View source

Related Articles

Legal Intelligence Newsletters: sign up for the latest legal and regulatory news on your chosen topics

Read more about

Related Comparative Guides

See more popular content from

Article

New York City’s Click-to-Cancel Rule: What Businesses Need To Know

New York City has enacted the nation's first municipal click-to-cancel rule, requiring businesses to provide clear disclosures, simple cancellation processes, and advance renewal notices for subscription services. With approximately 30 states already implementing similar regulations and the federal landscape in flux following the FTC's vacated rule, companies now face an increasingly complex patchwork of compliance obligations. The rule takes effect October 1, 2026, and imposes penalties ranging from $525 t
United StatesConsumer Protection
Skadden, Arps, Slate, Meagher & Flom LLP
Skadden, Arps, Slate, Meagher & Flom LLP
Article

FCC Replaces TCPA “Revoke All” Rule: New Category-Specific Opt-Out Rules For Robocalls And Robotexts

The Federal Communications Commission has fundamentally altered how businesses must handle consumer opt-out requests under the Telephone Consumer Protection Act, replacing the broad "revoke all" mandate with a more nuanced, category-specific approach for informational messages. This regulatory shift allows companies to maintain separate consent tracks for different types of non-marketing communications while preserving stricter opt-out requirements for telemarketing messages. The Updated Order introduces ne
United StatesConsumer Protection
Bass, Berry & Sims PLC
Bass, Berry & Sims PLC
Article

Amway To Pay $225 Million Over Alleged False Earnings Claims And Fabricated Sales

The FTC and Washington state secured a record $225 million settlement from Amway and affiliated groups over allegations they misled recruits about earnings potential while pressuring them to buy products with little retail opportunity. The complaint reveals that over three-quarters of U.S. product volume was sold to IBOs themselves rather than retail customers, with fabricated sales reporting masking the recruitment-driven model. The settlement's injunctive provisions establish new standards for earnings cl
United StatesConsumer Protection
Frankfurt Kurnit Klein & Selz PC
Frankfurt Kurnit Klein & Selz PC
Article

FTC Asks Whether Platform Ad Tools Fuel Impersonation Scams

The Federal Trade Commission is exploring whether digital platforms should bear greater responsibility for preventing impersonation ads that falsely pose as legitimate businesses or government agencies. Through an Advance Notice of Proposed Rulemaking, the agency seeks public input on potential amendments to its existing Impersonation Rule, examining how ad-optimization tools and platform practices...
United StatesConsumer Protection
Greenberg Traurig
Greenberg Traurig
Article

CONGRESS FIRES BACK?: New Bill Seeks To Revive Written Consent Rule Under TCPA

Congress has introduced the Stop Spam Calls Act, directing the FCC to revise the definition of prior express written consent under the TCPA to require one-to-one seller consent and logical relevance between sellers and website content. This legislative move comes as the Fifth Circuit questions whether written consent is even required under the TCPA, creating a fascinating tension between congressional intent and judicial interpretation that could reshape telemarketing compliance.
United StatesConsumer Protection
Troutman Amin LLP
Troutman Amin LLP
Article

The Coming State-Law Litigation Wave Of 2026-27: “Subscription Trap” Class Actions

State-law class actions targeting automatic renewal and subscription practices are accelerating, creating significant litigation risk for companies that rely on recurring revenue models. Recent settlements demonstrate that even technical compliance failures can lead to seven-figure exposure, with California, Illinois, and Virginia statutes driving the most aggressive litigation.
United StatesConsumer Protection
Benesch, Friedlander, Coplan & Aronoff LLP
Benesch, Friedlander, Coplan & Aronoff LLP
Article

FTC Announces Settlement And Articulates Knowledge Standard For Payment-Processor Liability

The Federal Trade Commission has reached a settlement with a payment processor and four affiliated entities over allegations that they knowingly facilitated deceptive merchants, including foreign tech-support operations, in accessing the U.S. card-payment system. The case resulted in a $4.85 million monetary judgment and features a significant Joint Statement from FTC leadership establishing a knowledge standard for unfair payment-processing claims under Section 5.
United StatesConsumer Protection
Greenberg Traurig
Greenberg Traurig
Article

Amendments To The Act On The Protection Of Personal Information Promulgated

Japan has enacted sweeping amendments to its Act on the Protection of Personal Information, introducing an administrative surcharge regime with monetary penalties for data protection violations, new protections for children under 16 and biometric data, and expanded exceptions for data utilization in statistical analysis and AI development. The reforms, which take effect in stages through 2028, fundamentally reshape Japan's privacy enforcement landscape by granting the Personal Information Protection Commiss
JapanPrivacy
A&O Shearman
A&O Shearman
Article

EU Packaging And Packaging Waste Regulation—what International Corporate Groups Should Know

The European Union's new Regulation on packaging and packaging waste has fundamentally transformed compliance requirements for companies placing packaged goods on the EU market, replacing decades-old directive-based frameworks with directly applicable product-law rules. While promising regulatory harmonization across member states, the reality presents a complex dual-compliance landscape where businesses must navigate both EU-wide packaging standards and diverging national implementation approaches.
European UnionEnvironment
A&O Shearman
A&O Shearman
Article

SEC Issues “Innovation Exemption” To Facilitate Trading Of Tokenized NMS Stock

The SEC has issued a groundbreaking Innovation Exemption allowing tokenized securities venues to facilitate trading of tokenized NMS stocks using automated market makers and liquidity pools. This temporary five-year exemption from exchange and dealer registration requirements establishes conditions for permissioned blockchain-based trading while granting public companies a 30-day window to object to third-party tokenization of their securities.
United StatesFinance and Banking
A&O Shearman
A&O Shearman
Article

Delaware Chancery Invalidates Buyer Termination And Orders Specific Performance Of Obligations To Seek Regulatory Clearance For Merger

A Delaware Court of Chancery decision examines whether an acquiror can terminate a $2.35 billion merger agreement when antitrust approval is delayed beyond the outside date. The case centers on whether the acquiror's abandonment of discussions with a competitor—which triggered an FTC investigation—constitutes "willful conduct" that prevents the buyer from walking away from the deal.
United StatesCorporate/Commercial Law
A&O Shearman
A&O Shearman
Article

Court Of Chancery Imposes Sanctions For Spoliation Of Signal Messages

The Delaware Court of Chancery imposed significant sanctions in a merger litigation case after finding that the company's controlling stockholder and senior officers recklessly destroyed Signal messages following legal hold notices. The court shifted the burden of proof by presuming certain facts favorable to plaintiffs, requiring defendants to rebut these presumptions with clear and convincing evidence rather than a preponderance standard.
United StatesLitigation, Mediation & Arbitration
A&O Shearman
A&O Shearman
Article

The EU’s Proposed Industrial Accelerator Act: What The Battery Industry Needs To Know—and Do

The European Commission's Industrial Accelerator Act proposes to reshape battery supply chains by conditioning access to EU public procurement and support schemes on strict origin requirements. As China controls over 80% of global battery manufacturing capacity, the legislation introduces escalating component-count thresholds that could fundamentally alter market access, financing structures, and supplier eligibility across the battery value chain.
GlobalGovernment, Public Sector
A&O Shearman
A&O Shearman
Article

How Spain’s Draft Data Center Rules Could Transform Digital Infrastructure Investment

Spain's draft Royal Decree introduces stringent energy sustainability, environmental, resilience and digital sovereignty requirements for data centers, including renewable additionality, hourly correlation, and efficiency standards. The regulation applies to all access and connection permits obtained after entry into force, with specific compliance deadlines for projects in progress and those with granted permits not yet connected to the grid.
SpainEnergy and Natural Resources
A&O Shearman
A&O Shearman
Article

California Passes Suite Of Bills Advancing Child Online-safety Push

California has enacted a comprehensive package of four bills that fundamentally reshape online safety protections for minors, targeting addictive design features, data privacy practices, age verification systems, and platform liability. These new laws establish strict requirements for social media companies, including mandatory stripped-down interfaces for users under 16, enhanced privacy defaults, and potential damages up to $1 million for negligent harm to children. The legislation represents one of the m
United StatesMedia, Telecoms, IT, Entertainment
A&O Shearman
A&O Shearman