The Financial Conduct Authority’s (FCA’s) mortgage market rule review roadmap, FS25/6, marks a clear next stage in the regulator’s thinking on how the mortgage market should work. It follows last year’s Discussion Paper, a great deal of industry feedback, and an open debate about advice, technology, and access to borrowing.
Like many in the market, I wanted to understand where this might realistically lead. Having read the roadmap, I then asked an artificial intelligence (AI) tool to review it alongside the Discussion Paper and consider what types of policy changes could flow from this work. There is, of course, a major caveat: the FCA has a lot of work to do across all four areas it plans to explore.
What follows is not a prediction, and certainly not certainty. It is an attempt to interpret the direction of travel and what it could mean for advisers over the next 12 to 18 months.
A regulator balancing advice and access
One of the strongest themes running through the roadmap is a tension the FCA has yet to fully resolve.
In later life lending, the FCA is clear. It wants consumers to make well-informed decisions and recognises that access to professional advice supports good outcomes. The language used here is firm and supportive of holistic advice.
At the same time, the regulator appears increasingly comfortable with other borrowers, often younger and existing customers, taking mortgage decisions with less adviser involvement. The removal of the advice interaction trigger remains the clearest signal of this. The FCA continues to say that decision was justified.
For advisers, this contrast is difficult to ignore. If holistic advice is right for older homeowners, it is reasonable to ask why it would not also improve outcomes for all mortgage customers?
What the roadmap suggests could change
Based on the roadmap and the earlier Discussion Paper, what might be the key areas for advisers to be aware of?
First, there may be a further shift away from adviser-led intervention for existing borrowers. The roadmap talks about flexibility, innovation, and reducing friction. That could mean more scope for execution-only routes, fewer prompts back to advice,
and greater freedom for lenders to manage retention journeys directly. Advice would still exist, but it may no longer be the default starting point in many cases.
Second, the FCA appears to be pushing towards more joined-up, or holistic, thinking, in later life lending. It does not want new silos or tiers of advice, but it does want better consideration of wider outcomes. This could lead to higher expectations around training, disclosures, referrals, and record keeping, even for firms that do not advise on every option. The intention may be sound, but the practical impact on adviser workload and risk remains unclear.
Third, technology and AI are likely to play a larger role. The roadmap frames AI as a support tool for consumers and advisers, not a replacement for advice. It stresses advisers should retain responsibility for the final decision.
That is reassuring, but it also assumes a stable end point. Progress in this area is rapid, and at some stage the regulator may become comfortable with outcomes that are shaped almost entirely by automated processes.
Advisers as validators?
One line in the roadmap also felt particularly striking. It suggests that intermediaries could increasingly act as ‘interpreters, validators or facilitators’ of AI-generated outputs.
That raises an uncomfortable question. If advisers are simply validating a list produced elsewhere, are they still advisers, or do they become introducers in all but name?
It also raises a practical issue around fees. Would a customer be willing to pay for a service that feels like having their homework checked? If AI produces the shortlist and the adviser confirms it, how does that support a sustainable charging model?
This is not an argument against technology. Used well, AI can support better outcomes and improve efficiency. But if advisers are pushed too far from the centre of the decision, the value of advice risks being diluted in the eyes of consumers.
Where consumer protection fits
This matters because advice brings structure, accountability, records, and access to redress. AI-led or self-directed routes do not offer those protections in the same way.
The FCA places strong emphasis on vulnerable customers, yet vulnerability is not limited to age. Income shocks, health issues, family change, and financial stress
affect borrowers across the market. One could argue that the later life lending approach, where advice is clearly supported, may actually be the right model for all mortgage customers.
Credit for listening, but questions remain
It is fair to say the roadmap shows the FCA has listened to industry feedback. The concern that advice was being pushed aside feels less likely now. The tone is more balanced, and the value of advice is recognised. Thoughts of introducing an ‘enhanced advice’ category have been jettisoned.
However, reassurance is not the same as clarity, and we must wait months, perhaps even years, to get this in a number of areas.
The real question for advisers
The mortgage market is not facing sudden disruption, but it is shifting. There is plenty of business to be written. Clients still need help. Lenders still want volume. The question however is not whether the business is there, it is who controls it.
Advisers who focus on relationships, complex cases, and wider planning are likely to be more resilient than those relying on simple retention alone. Support will matter. Advisers will need access to distributors, but also other specialists, plus compliance and training tools, and insight to adapt early rather than react late. They will also need a clear voice when policy and lender decisions affect their role.
The FCA has set out a roadmap, not a rulebook. There is still consultation, research, and debate ahead across all areas it plans to explore. The outcome is not fixed. What is clear is that the value of advice will need to be demonstrated, not assumed. How well that value is recognised in future policy will shape the adviser market for many years to come.
Richard Howes is managing director at Paradigm Mortgage Services
