FCA PS25/22 Targeted Support · Live 6 April 2026

Disciplined investing,
in plain English,
for everyone.

VesperAI delivers FCA-regulated investment guidance to the 23 million UK adults who have never received a professional recommendation — at the cost of a streaming subscription.

23M
UK adults with investable assets receiving no regulated financial advice
£644bn
Unadvised assets in Cash ISAs and unguided workplace pensions
9%
UK adults who take financial advice in any two-year window — Mark Duckworth, Schroders Personal Wealth, March 2026
"Only 9% of UK adults take financial advice over any two-year window. There are now only 28,000 financial advisers — down from 230,000 in 1990."

Mark Duckworth · Group CEO, Schroders Personal Wealth
Investment Association EnTech Global Conference · London, March 2026

The advice gap is not a consumer choice. It is a structural failure of regulation and pricing. The FCA has formally acknowledged this — and created the mechanism to fix it.

£1,500
Minimum cost of a regulated financial plan — putting professional advice out of reach for most households
12M
UK adults with unused £20,000 annual ISA allowances — £75bn sitting in cash earning below inflation
4.3M
Dormant workplace pension pots in the UK — average value £13,000, no guidance, no rebalancing
28k
Registered financial advisers in the UK today — down from 230,000 in 1990 as regulation and costs increased
The regulatory moment

A once-in-a-decade unlock

FCA Policy Statement PS25/22 created Targeted Support — a new regulated category live from 6 April 2026. For the first time, authorised firms can deliver personalised investment suggestions without conducting individualised suitability assessments. VesperAI is built from the ground up for this regime.

Where VesperAI sits

Between generic guidance and full personal advice sits a new regulated category that changes everything for mass-market investing. Vesper's FCA authorisation application is in progress — we are positioned to be among the first firms operating under this permission.

Category 1
Information & Guidance
Generic content anyone can provide. No personalisation. No regulated permission required.
Category 2 — New from 6 April 2026
Targeted Support
Ready-made suggestions suitable for consumer segments with common characteristics. FCA authorisation required. No individual suitability assessment needed.
◆ VesperAI operates here
Category 3
Simplified Advice
Individual suitability assessment for a limited range of products. Significant regulatory overhead.
Category 4
Full Personal Advice
Holistic financial planning. Individual suitability assessment. Minimum £100,000 assets. £1,500–£5,000 per plan.

VesperAI is not a chatbot.
It is a compliance-first ETF guidance engine
with a conversational interface.

Core principle: Claude generates language. A Python rules engine generates numbers.

All investment scores, segment assignments, and ready-made suggestions are produced by a deterministic rules engine — not by AI. Anthropic Claude generates only the natural language explanations. The result is a PS25/22-compliant system that cannot hallucinate, cannot give personal advice, and is fully auditable end-to-end.

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Conversational profiling

A 7-question bounded-choice dialogue. Consumers select from fixed options at every turn. No free-text input. No NLP. Every path pre-defined and FCA-documented.

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Deterministic scoring

5-factor composite model: 12M momentum, 3M momentum, quality (Sharpe), volatility-inverted, dividend yield. Scores recalculated quarterly from live market data. SMF16 sign-off required.

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Durable medium output

Every session produces an FCA-compliant disclosure document: segment rationale, ETF allocation, mandatory Consumer Duty disclosures, and a capital-at-risk statement. Emailed to the consumer.

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Kill switches

High-interest debt check at Turn 4: session halts, MoneyHelper link provided. Vulnerability pathway at Turn 7: profiling stops, signposting only. Both are deterministic — no AI decision-making.

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SYSC 9 audit trail

Every session logged in real time: 17-field JSONL schema, unique Session ID, ISO 8601 timestamps, every turn recorded. Available for FCA inspection on request.

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Compliance monitor

18-check automated ruleset runs on every session: 10 deterministic checks + 8 AI-assisted checks. HIGH severity findings escalate to SMF16 before the durable medium is issued.

The consumer journey

From first question to ready-made suggestion

1
Consent & Disclosure
Dual-checkbox consent: PS25/22 Targeted Support disclaimer + GDPR Article 13 notice. Session cannot proceed without both.
2–7
Risk Profiling
7-question bounded-choice dialogue. Objective, horizon, financial situation, debt check, risk capacity, risk tolerance, vulnerability check.
Segment Assignment
Deterministic rules engine calculates composite score. Segment assigned: Capital Preservation / Cautious / Balanced Growth / Growth.
Ready-Made Suggestion
ETF allocation delivered with plain-English explanation. Durable medium emailed. SYSC 9 log written. Compliance monitor runs.
Two mandatory kill switches: If a consumer discloses high-interest debt at Turn 4, the session halts immediately and the consumer is redirected to MoneyHelper — no segment is assigned. If a vulnerability indicator is disclosed at Turn 7, VesperAI routes to a signposting-only Vulnerability Pathway — no investment suggestion is made. Both switches are deterministic and cannot be bypassed.

Four segments. Eight instruments. Academically grounded.

All eight ETFs are LSE-listed, UCITS-compliant, and available through mainstream UK investment platforms. The 5-factor composite scoring model is independently consistent with published multi-factor research from Research Affiliates and Asness, Frazzini & Pedersen (2019).

Growth
+30.0%
BRWM · EIMI · VWRL
12-month blended return
Above VLS 80% (+23.7%)
Balanced Growth
+16.5%
VWRL · ISF · EIMI · IMEU
12-month blended return
Between VLS 60% and VLS 80%
Cautious
+6.2%
ISF · INXG · VWRL · WMVG
12-month blended return
Above BoE cash rate (4.5%)
Capital Preservation
+2.9%
IGLT · INXG · WMVG
12-month blended return
Above UK Agg Bond (+2.1%)

Data: Yahoo Finance · Period: 21 March 2025 – 20 March 2026 · Risk-free rate: 4.5% p.a. · Past performance is not a reliable indicator of future results. Capital at risk.

Governance & compliance

Compliance is our competitive moat,
not our constraint.

VesperAI's 18-check Compliance Monitor runs automatically on every session — before the durable medium is issued. 10 deterministic checks verify the structural integrity of each journey. 8 AI-assisted checks assess tone, language, and compliance boundary.

DKill switch triggered on high-interest debt disclosure
DVulnerability pathway triggered where indicated
DDual-checkbox consent confirmed before profiling
DDurable medium generated for every completed session
DAll 7 profiling turns completed before segment assigned
DETF suggestion within approved universe (8 instruments)
AIAdvice boundary — no language suggesting personal advice
AIPlain language — explanation accessible to target consumer
AIConsumer vulnerability signal detection
AIDurable medium accuracy — allocations match rules engine output

Three lines of defence

First line — VesperAI system

Deterministic rules engine. 18-check Compliance Monitor. SYSC 9 audit logging on every session. Bounded-choice dialogue prevents free-text AI output.

Second line — SMF16 Compliance Oversight

Quarterly scoring model review and sign-off. Ad hoc material event review (VIX >40, ETF moves >20% in 30 days). Kill-switch authority. Compliance Officer (CF10) from Month 4.

Third line — External audit

Annual Consumer Duty audit by qualified third-party reviewer. Ongoing FCA supervisory relationship. Bovill Newgate engaged as regulatory counsel.

Pre-launch evidence pack

30,000-session synthetic journey test programme before go-live. 56–68 structured consumer qualitative testing sessions. Customer Testing Methodology documented and available for FCA review.

Compliance infrastructure
for the financial services industry.

Vesper's B2B2C model makes VesperAI available as licensed compliance infrastructure for IFAs, wealth platforms, and financial services firms who face the advice gap but lack the technology or regulatory permission to deliver Targeted Support at scale.

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IFAs & Adviser Networks

VesperAI handles the Targeted Support layer — freeing your advisers to focus on the clients who need full personal advice. We hold the PS25/22 permission. You retain the client relationship.

SaaS licence + per-session fee
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Investment Platforms

Embed VesperAI as a white-label Targeted Support layer within your existing platform. Your brand, your customer journey, our compliance infrastructure and FCA permission.

Annual licence + volume fee
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Employers & Employee Benefits

Financial wellbeing at scale. VesperAI provides employees with regulated investment guidance as a workplace benefit — driving ISA and SIPP engagement at zero cost to the employee.

£5 / employee / month
The team

Built by people who understand
regulation and technology in equal measure.

RM
Ram Morjaria
Founder & CEO · Chartered Accountant

Ram brings 30 years of business building experience, including seed fundraising for multiple companies through the Welsh Government High Growth Programme and angel investor syndicates. His conviction that compliance should be a competitive moat — not a constraint — shapes every architecture decision at Vesper.

FCA PS25/22 regulatory strategy
Agentic AI development and product design
Welsh Government High Growth Programme
Angel investor and seed fundraising experience
Regulatory counsel: Bovill Newgate

We're building the team

Vesper is actively recruiting for two founding roles. If you have the experience and want meaningful equity in a first-mover regulated fintech, we want to hear from you.

Technical Co-Founder / CTO
5+ years fintech engineering · Python + React/React Native · Anthropic API · Compliance engineering (audit logging, GDPR, SOC 2) · Equity: 20–35%
Head of Compliance & MLRO (SMF17 / CF10)
CF10 certified · FCA Consumer Duty and MLR 2017 experience · 2–3 days per week · Meaningful equity stake · Start: Q2 2026
Send your CV →

Raising £150,000–£400,000 on a SAFE / Convertible Note. Valuation cap £1.5M–£2.5M. SEIS eligible — 50% income tax relief. Seed round target £750k–£2M (EIS) follows FCA PASS engagement.

Request the investor deck →

Let's talk about
the advice gap.

Whether you're an investor, a potential B2B2C partner, a compliance professional considering joining the team, or an IFA firm exploring Targeted Support — we'd like to hear from you.

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Wales, United Kingdom · Vesper Financial Technology Ltd
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Registered in England & Wales · Regulatory counsel: Bovill Newgate
Important regulatory information. Vesper Financial Technology Ltd is in the process of applying for FCA authorisation to provide Targeted Support under PS25/22. VesperAI is not currently authorised to provide regulated investment guidance and does not currently accept clients. Nothing on this website constitutes financial advice or a personal recommendation. The ETF performance data shown is historical and does not guarantee future results. Capital is at risk.

Vesper Financial Technology Limited is registered in England and Wales. Companies House registration in progress. FCA authorisation application pending. Regulatory counsel: Bovill Newgate LLP.