FCA CONSULTATION · CP26/24
A Fees “Food Label”: Why the FCA’s New Fee Disclosure Proposals Should Go One Step Further
SCM Direct – policy commentary. Consultation closes 21 August 2026
On 2 July, the Financial Conduct Authority published CP26/24, its consultation on simplifying the disclosure of the cost of investing. It is a serious and, in most respects, welcome piece of work.
The direction of travel is right. Before the point of sale, firms would be required to break down the key components of cost — the product charge, the service or platform fee, and explicit transaction costs — and present a total figure in both pounds and percentage terms, personalised and annualised for the individual customer.
Post-sale, consumers would see the actual impact of costs on their returns over the service’s lifetime. The regulator has also, at last, drawn a firm line under “double-dipping” on cash: interest rates paid on cash will have to be published, and any fees applied to cash balances will have to be disclosed plainly. On all of this, credit where it is due.
You cannot compare what is not presented comparably. And you cannot have a competitive market without knowing the price.
The one thing missing
But there is a tension at the centre of these proposals that we at SCM Direct would be failing our clients if we did not name.
The defining feature of the new regime is a deliberate move away from prescriptive templates and towards “flexibility” and what the FCA repeatedly calls “dynamic” disclosure. In the regulator’s own words, it has stripped away templating to allow firms to innovate and communicate in more engaging ways. Much of the industry has welcomed this, and the instinct is understandable. The old forty-page documents, dense with jargon, served almost no one. The FCA’s own review found that just 6% of the 132 pre-sale documents it examined were written in plain English, and every single one was pitched above GCSE reading level.
The lesson many have drawn is that prescription failed. We would draw a different one.
The problem was never simply that disclosure was long. It was that costs were hidden, inconsistent, and impossible to compare like for like. Flexibility, on its own, does not solve that. It risks trading one comprehension problem for another. Nearly a third of people investing through a platform without advice already say they do not know what they are being charged. If every firm is now free to present its costs in its own format, in its own place, at a moment of its own choosing, how is that investor supposed to hold two options side by side and see which is genuinely better value?
The case for a label — and the industry’s objection to it
The industry’s resistance to a mandated form and format is long-standing and, in fairness, not baseless. A fixed template, the argument runs, stifles innovation, cannot flex across very different products, and imposes cost. Some of that is true. No one wishes to reanimate the KIID.
But consider how we solve this problem precisely everywhere else in a consumer’s life. We do not ask a shopper to read the full manufacturing history of every item on the shelf. We give them a nutrition label: standardised, in a specified place, in a specified format, so that one tin can be compared with the one beside it in seconds. The label does not dictate the recipe. It simply tells you honestly what is inside.
Investors deserve exactly this. Investment costs shown in a single, standardised fees label — total all-in costs, in both pounds and percentage, in a prescribed format and a prescribed place, shown before the point of purchase. It is the minimum a functioning market requires. Flexibility should govern how a firm educates, engages and explains. It should not govern whether the headline price is comparable. On that one thing, and that thing alone, prescription serves the consumer.
We have made this argument before
This is not a new position for us. When our Founders, Alan and Gina Miller, started the True & Fair Campaign in 2012, its centrepiece was precisely this idea: a True & Fair Label, modelled directly on food labelling, giving every investor a single, honest, comparable figure for the true cost of their investment. That campaign — funded entirely by its founders, with no external backers — helped drive reforms on closet index tracking, hidden fees and fund labelling, and shaped text now embedded in three European directives: Article 24 of MiFID II, PRIIPs and the Shareholder Rights Directive.
It has taken thirteen years, via CP26/24, for the FCA, the regulator, to move towards the spirit of that argument. The insistence on all-in costs, in pounds and percentage, personalised to the customer, is genuine progress. The ban on double-dipping is overdue and right. What remains is the final step: standardising the label itself, so that a consumer can compare one firm against another at a glance. That is the step that will really deliver the consumer understanding the Consumer Duty demands, rather than leaving it to the design choices of individual firms.
What happens next
SCM Direct will respond to the consultation before it closes on 21 August 2026, ahead of the FCA’s policy statement, expected by the end of the year, and its implementation from June 2027.
Our response will make the case we have made for over a decade: for a simple, standardised, prominently placed fees label — a cost label for your money — sitting alongside, not instead of, the clearer and more dynamic disclosures the FCA rightly wants to encourage.
We would encourage every firm that genuinely puts its customers first to argue the same. At SCM Direct, we have always shown our costs in full, in one place prior to purchase, and for clients in pounds and pence. In addition, our Founders invest their own money in the same portfolios, on the same terms and the same fees as our clients. Transparency, for us, has never been a compliance exercise. It is a fundamental essential.
The SCM Direct Team
This article is general commentary on regulatory policy and does not constitute personal financial advice. SCM Direct is a trading name of SCM Private LLP, which is authorised and regulated by the Financial Conduct Authority (No. 497525).
