Comment on FS25/6 and the future of mortgage advice

15 December 2025

Seb Murphy, Group Director at JLM Mortgage Services said:

“FS25/6 has some clear positives for advisers. The FCA is right to step back from enhanced advice and to say it supports holistic advice. A two-tier system would have caused real confusion and risked pushing clients down the wrong path. That decision matters.

"There are also real opportunities here. A fresh look at later life lending, RIO affordability, interest-only options and how irregular income is treated could help more clients borrow in a sensible way. But none of this makes advice less important. It makes it more important.

"My concern is not what the FCA says it wants, but how this could play out in practice. Giving lenders more freedom on product design, disclosure and customer journeys must not lead to advice being treated as optional, or something to add later if problems appear. Talk of ‘tolerable harm’ and rebalancing risk needs to stay rooted in real outcomes for real people.

"If access is widened, advice standards must hold firm. Faster journeys and more choice are fine, but they need clear signposting to advice and strong checks for complex cases. Otherwise we risk repeating old mistakes, just in a more digital form.”