A survey of financial sector participants has identified a marked difference between how prepared businesses feel for the proposed Conduct of Financial Institutions Bill (COFI) and the extent to which they have begun formal preparation.
The September COFI Readiness Survey, conducted by Old Mutual Personal Finance and FAnews, found that 62.4% of respondents were following COFI fairly or very closely, and 60% felt prepared. However, only 16% were very confident that they understood the likely implications for their businesses, while just 23.2% had started formal preparation.
The difference between perceived readiness and reported formal preparation is 36.8 percentage points, highlighting the distinction between feeling prepared and having begun a structured process.
The survey received 129 responses between 1 and 11 September 2026. Respondents included advisers, brokers, financial services provider owners, compliance professionals, and other industry stakeholders. The report describes the findings as a directional industry pulse rather than a statistically representative study of the market.
Keith Peter, advice manager at Old Mutual Personal Finance, said following COFI developments was an important first step, but it did not necessarily mean a business was ready to respond.
“Advisers need to start assessing how the proposed requirements could affect their day-to-day operations, from client onboarding and advice processes to client communication, record-keeping, systems, and governance. A structured review can help firms identify potential gaps, prioritise areas requiring attention, and determine what further guidance they may need,” he said.
Practical clarity remains limited
The survey found that 47.2% of respondents still needed more practical detail. This suggests that following developments around the proposed legislation has not necessarily given businesses sufficient practical clarity to assess what preparation may be needed.
Uncertainty appears to be a leading obstacle. The report found that 41% of respondents were waiting for greater clarity, while 35.2% identified understanding what was required as a barrier.
Old Mutual Personal Finance added that time and internal capacity were each cited by 7.2% of respondents, while cost was cited by 4.8%.
Most respondents had engaged with webinars, industry sessions, articles, and regulatory updates. However, fewer had reviewed their systems, data, record-keeping, or advice processes, or conducted a formal gap analysis.
Peter said the distinction between understanding the proposed legislation and assessing its practical implications mattered.
“Without a clearer view of existing processes and potential gaps, firms may struggle to determine where to focus their preparation and what changes, if any, their businesses may need,” he said.
Smaller practices feature prominently
The respondent profile provides context for the concerns about the possible impact of COFI on smaller businesses. Almost two-thirds of respondents, 64.5%, worked in independent advice practices or brokerages. More than half, 51.2%, operated alone or in firms with between two and five advisers.
Short-term insurance brokers made up 35.5% of respondents, while financial advisers accounted for 26.4%. Key Individuals represented 10%, and FSP owners or principals accounted for 9.1%. These selected roles do not add up to 100%, and the survey also included compliance professionals and other industry stakeholders.
The survey does not establish that smaller practices are less prepared than larger institutions. However, Old Mutual Personal Finance observed that smaller practices may have fewer dedicated compliance, legal, risk, and technology resources to support regulatory preparation.
Additional administration and reporting was the most selected COFI concern, identified by 49.6% of respondents. The impact on smaller practices was selected by 41.9%, licensing changes by 31.8%, and increased compliance costs by 29.5%.
Old Mutual Personal Finance said the proposed regulatory requirements and supervisory approach were expected to take account of the nature, size, complexity, and risk profile of different financial institutions. The company said this proportional approach would be important in enabling smaller practices to understand and meet their obligations without facing unnecessarily onerous compliance requirements.
Communication needs to be easier to apply
Respondents’ concerns about understanding what COFI may require were accompanied by criticism of existing communication. The report found that 78.4% identified at least one shortcoming in COFI communication, describing it as insufficiently clear, difficult to interpret, or not practical enough.
Old Mutual Personal Finance added that only 16% of respondents described existing communication as very clear and practical. The report does not establish that this figure and the 78.4% finding are complementary categories.
When respondents were asked what forms of support they wanted, 58.1% selected a plain-language COFI overview, and 55.8% chose a practical readiness checklist. Guidance for smaller FSPs was selected by 30.2%, while 28.7% wanted webinars featuring practical examples.
A separate question asked respondents to select the single resource that would be most useful immediately. A “Where do I start?” checklist was the leading choice at 31.5%, followed by a small-business readiness guide at 22.6%. Together, these two choices accounted for 54.1% of responses.
The results point to demand for resources that translate COFI information into practical steps businesses can use to assess their readiness.
Reviewing existing practices
Peter said firms could start by reviewing their current business practices and identifying areas that may require closer attention as greater regulatory clarity emerges.
“This could include examining how clients are onboarded, how advice is delivered and documented, how information is communicated to clients, and whether record-keeping, systems and governance arrangements adequately support these processes,” he said.
An initial review could help firms to understand their existing processes, identify potential gaps, and formulate questions for their compliance professionals. Peter said firms could prioritise these questions and monitor further regulatory guidance rather than waiting for every detail to be settled before beginning an assessment.
