Every rule in the graph carries the TSM requirement ID(s) it implements at the start of its
name, so traceability is bidirectional and mechanical. This document maps Direction 1
(every rule → its requirement(s) → the regulatory source) and Direction 2 (every research
source → the TSM requirements it grounds → the rules that implement them).
Every mapping below was verified against the live primary sources on
30 August 2026. The primary sources are:
- SI 2026/74 inserting RAO article 55A (legislation.gov.uk — uksi/2026/74 and
uksi/2001/544/article/55A);
- FCA Handbook COBS 9B (handbook.fca.org.uk/handbook/cobs9b, sections 9B.1–9B.10, in
force 6 April 2026, instrument FCA 2026/5);
- FCA PS25/22 (published 11 December 2025; final rules made 26 February 2026);
- FCA good and poor practice — "Targeted support: firm considerations when designing
consumer segments", 23 March 2026;
- FCA/ICO and FCA/FOS joint statements, 11 December 2025;
- PECR regulation 22 (uksi/2003/2426/regulation/22);
- FG21/1 — FCA guidance on the fair treatment of vulnerable customers;
- DUAA 2025 — UK GDPR articles 22A–22D (ukpga/2025/18/section/80, in force
5 February 2026).
Rule names below are verbatim from graph.xml (280 distinct TSM-prefixed rule names,
each occurring exactly once, plus 6 "Evidence …" rules). The register is the first
section below.
Where a requirement is a firm calibration with no FCA figure, the source column says Firm
policy explicitly.
Requirements register
Every requirement carries a TSM ID. Rule names in the graph carry the TSM IDs of the
requirements they implement, so traceability is bidirectional: this register → rules
(via the coverage map in the Direction sections below) and rules → this register (via rule
names). Sources are the final Handbook rules effective 6 April 2026, the RAO amendment,
the FCA/ICO and FCA/FOS joint statements, FG21/1, and the Consumer Duty (PRIN 2A).
Verification status is reconciled in the source mappings below.
1. Perimeter, permission and client status (TSM-101 — TSM-118)
- TSM-101 A firm may provide targeted support only with the Part 4A permission for
the new RAO article 55A regulated activity. An article 53 advising permission does NOT
authorise it. Source: RAO art 55A (SI amendment), FCA PS25/22.
- TSM-102 Appointed representatives may not provide targeted support. Source:
COBS 9B.2.4G verbatim ("Providing targeted support is not permitted business of
appointed representatives"); HMT did not extend the AR regulations to the activity.
- TSM-103 COBS 9B applies to targeted support on designated investments (including
pensions) other than pure protection. Source: COBS 9B.2.
- TSM-104 Subject matter within article 55A but outside COBS 9B scope falls back to
the advising rules. Source: COBS 9B.2 / PERG.
- TSM-105 Absolute prohibition on targeted support where the consumer holds
safeguarded benefits (DB rights). Source: COBS 9B.2.3R.
- TSM-106 A guaranteed annuity rate is treated as a safeguarded-benefit indicator —
FIRM POLICY reading (cf 90), Handbook glossary perimeter unresolved.
- TSM-107 The client is treated as a retail client for the service regardless of
categorisation; COBS 9/9A suitability does not apply. Source: COBS 9B.3.
- TSM-108 No individual suitability determination is made or asserted. Source:
art 55A(4), COBS 9B.
- TSM-111 The suggestion must be "presented as suitable for the individual on the
basis of the individual being in the group" (art 55A(3)(b)(iii) verbatim), and the
article 55A(4)/(5) statement must accompany it, or the article 55A(2) carve-out from
article 53 fails (advising without permission). Source: RAO art 55A(2)-(5).
- TSM-112 The regime applies from 6 April 2026; earlier cases are out of scope.
- TSM-113 The client must be a natural person (retail consumer).
- TSM-114 Rights under trust-based occupational pension schemes are outside the RAO
specified-investment perimeter for this activity.
- TSM-115 Territorial scope: UK consumers (COBS territorial application).
- TSM-116 (covered within TSM-101/102 rules) Perimeter is a POSITIVE determination —
unknown data never places a case inside the perimeter.
- TSM-118 Duties and liability to the client must not be excluded or restricted; a
liability disclaimer in the disclosure set is a compliance defect. Source: COBS 9B.1/2
guidance and PRIN.
- TSM-121 Two-limb relevance test: every common characteristic must be (a) shared and
(b) relevant to the specification of the suggestion. Source: COBS 9B.4.16R(2).
- TSM-123 Calibration of the contra-indication gate recorded: firms are not expected
to trawl all data they hold. Source: COBS 9B.5.11R with 9B.5.12G.
2. Initiation, consent, marketing — the ICO/PECR layer (TSM-131 — TSM-138, TSM-201 — TSM-210)
- TSM-201 Targeted support may be initiated by the firm only on an express client
request or on reasonable grounds that the client is in an addressed situation. Source:
COBS 9B.5.3R.
- TSM-202 A service availability notice is not initiation of the service.
- TSM-203 A client election not to receive targeted support is an absolute stop,
distinct from the marketing objection. Source: COBS 9B / Consumer Duty.
- TSM-204 A ready-made suggestion sent by electronic mail to an individual is direct
marketing: PECR reg 22 requires consent (or soft opt-in); consent must be granular and
unbundled (UK GDPR standard). Source: FCA/ICO joint statement, PECR.
- TSM-205 Broadcast (website/in-app to all customers) and non-electronic-mail channels
are outside the PECR electronic mail rule.
- TSM-206 A neutral factual awareness message may be sent without marketing
permission; it cannot carry a suggestion.
- TSM-207 Service messages are not direct marketing.
- TSM-208 Workplace pension member soft opt-in route: HMT committed to an extending
SI, but as of 30 August 2026 it has NOT been laid or made — the route is PENDING
LEGISLATION and NOT usable. The model must NOT grant marketing permission through it;
it records the route as unavailable-pending-legislation instead.
- TSM-209/210 Cross-regime record: a message engineered to be non-marketing for PECR
may still be a financial promotion for COBS 4; both tests recorded.
- TSM-131 An objection to direct marketing blocks an electronic-mail suggestion.
- TSM-132 Granular consent record requirement (firm-level).
- TSM-137 Aggregable MI fields for the FCA periodic data request (outcome,
classification, suggestion delivered, opt-outs).
- TSM-138 Reporting classification: retirement income vs non-advised product sales.
3. Consumer data sufficiency (TSM-301 — TSM-317, TSM-1901 — TSM-1907)
- TSM-301 A segment must specify the information required to establish alignment
(COBS 9B.4.17R); a segment specifying none is design-defective.
- TSM-302 Required information missing or not current → alignment cannot be
confirmed; data request issued.
- TSM-303 Data beyond its per-item staleness window must be verified with the client
before alignment is confirmed. Source: COBS 9B.5.7R.
- TSM-304 Contradictory current records for a required data item must be resolved
before a suggestion; record ordinals mirrored as string marks for distinct counting;
ordinal integrity checked.
- TSM-305 Record which provenance supported each characteristic (supervisory file).
- TSM-306/307 Data that is not readily accessible (credit card history, transaction
pattern analysis — FCA poor practice) can never be required for alignment.
- TSM-311 Assumptions must be reasonable, referable to evidence about the covered
individuals, and immaterial to suitability. Source: COBS 9B.4.11R.
- TSM-317 Risk tolerance and capacity for loss are client-stated, banded, never
assumed.
- TSM-1901/1902 Provenance asymmetry: weak provenance (firm inference, third-party
feed) may support an excluding characteristic but may not establish an including one.
Explicit negatives always require the underlying record to be present.
- TSM-1907 Unknown safeguarded-benefit status on a pension case fails safe to the
COBS 9B.2.3R stop (cf 85).
4. Segment design and qualification (TSM-401 — TSM-413, TSM-1905)
- TSM-401 A segment must be defined by reference to a consumer situation involving a
shared financial support need. Source: COBS 9B.4.4R.
- TSM-402 Exactly one ready-made suggestion per segment. Source: COBS 9B.4.5R.
- TSM-403 A design-defective segment must never be used for alignment; a matching
defective segment is routed to governance, and blocks the case only where no compliant
segment is confirmed.
- TSM-404 Including characteristics must be POSITIVELY confirmed; excluding
characteristics must be positively RESOLVED (present or explicitly absent); unresolved
exclusions block qualification. Source: COBS 9B.5.5R.
- TSM-405 A single excluding characteristic held blocks alignment. Source:
COBS 9B.4.16R(1) with 9B.5.5R.
- TSM-406 Within one situation only one segment may align; two or more qualifying is
a design defect of the segment set. Source: COBS 9B.4.7R.
- TSM-408 Granularity floor: segments must be sufficiently granular (situation-scaled
minimum characteristic count); a segment with no including characteristics would match
everyone. Source: COBS 9B.4.9R(1).
- TSM-409 Comprehensive-consideration ceiling: too many characteristics approaches
individualised advice. Source: COBS 9B.4.9R(2).
- TSM-411 Age-band characteristics from policy-held band edges (data-driven).
- TSM-412 Total pension provision measured on the total, not per-pot features.
- TSM-413 Characteristics flagged poor practice for a situation by the FCA are design
defects when used. Source: FCA good and poor practice material.
- TSM-414 A segment must be referable to evidence about the type of individuals it
covers: a segment with no recorded prevalence rationale is design-defective. Source:
COBS 9B.4.11R evidence limb with the FCA good practice on segment design.
- TSM-1905 At most one suggestion per case: firm-defined situation priority selects
one aligned situation; the rest are recorded as deferred.
5. Exclusions, vulnerability, contra-indication (TSM-501 — TSM-512)
- TSM-501 Readily accessible information indicating the suggestion may be unsuitable
prohibits delivery. Source: COBS 9B.5.11R.
- TSM-503 FG21/1 vulnerability drivers (Health, Life Events, Resilience, Capability)
detected from CRM record or client disclosure.
- TSM-504 Referral-severity vulnerability indicators stop the service and route to
specialist support; vulnerability may determine whether to provide support at all.
Source: COBS 9B.7.4G, FG21/1.
- TSM-505 Adjusted-delivery indicators deliver with adjustments.
- TSM-507 Problem debt / no emergency fund are excluding characteristics (financial
resilience).
- TSM-508 Significant health issue affecting life expectancy is an excluding
characteristic for decumulation segments.
- TSM-509 Emergency fund presence is a derived CHARACTERISTIC, never an assumption.
- TSM-510 Concurrent/recent advice is not a bar; it requires the advice distinction
to be explained and confirmed. Source: COBS 9B.6.16G.
- TSM-511 Information volunteered by the client during the interaction is information
the firm IS aware of (COBS 9B.5.11R "is, or ought reasonably to be, aware"): the firm
must route it — terminate the journey, seek clarification and re-align, or continue
where suitability is unaffected — and an unrouted volunteering blocks delivery.
- TSM-512 Firm-policy exclusions: capacity not established, under minimum adult age,
third-party represented (the third-party exclusion applies to the protective segment
exclusion sets alongside the capacity exclusion).
- TSM-514 A client request to transact inconsistently with the suggestion is recorded
and processed outside targeted support as client-directed business (firm policy).
6. Suggestion selection and product scope (TSM-601 — TSM-618)
- TSM-601 The single suggestion delivered is the one specified for the selected
segment, after clearing every block.
- TSM-604 Prohibited investment categories may not be suggested. Source: COBS 9B.4.42R.
- TSM-605 Complex, illiquid or volatile non-packaged products unlikely suitable for a
limited information service. Packaged products containing restricted components are NOT
prevented (encoded: the block requires product is packaged = false), and sell
recommendations are not prevented. Source: COBS 9B.4.43G.
- TSM-606 Express consolidation recommendations prohibited. Source: COBS 9B.4.38R
(the rule covers express OR implied).
- TSM-607 Implied consolidation (transfer into an existing arrangement; transferring
multiple arrangements into a new one) prohibited. Source: COBS 9B.4.38R with the
9B.4.39G definition.
- TSM-608 A single-pot transfer to a NEW provider is NOT consolidation (encoded: the
block fires only on the 9B.4.39G shapes, so both flags false raises no block). Source:
COBS 9B.4.40G. Multi-pot support without consolidation is permitted (segment S11).
Source: COBS 9B.4.41G.
- TSM-610 Annuity suggestions: no particular annuity, no quote, features only.
Source: COBS 9B.4.28R.
- TSM-612 The interaction ends after an annuity suggestion; any sale is a separate
journey. Source: COBS 9B.4.32R.
- TSM-613 Annuity brokerage referral only after the interaction ends, after the prior
annuity rules are met, after a reasonable opportunity to use the MoneyHelper
comparison, with NO quote accompanying the referral, and only to a brokerage offering a
sufficient range (9B.4.35R; whole-of-market not required, 9B.4.36G — the
sufficient-range attribute is firm registry configuration). Source: COBS 9B.4.33R.
- TSM-616 Product costs, target market consistency and provider financial strength
must be evidenced for the suggestion. Source: COBS 9B.4.24G.
- TSM-618 A product with a significant adaptation notice must be reviewed before
further suggestions. Source: COBS 9B.10.6R.
7. Segment suitability and better position (TSM-701 — TSM-708)
- TSM-701 Better position: the firm must have reasonable grounds to consider that
consumers in the segment would be in a better position than without the support —
GUIDANCE, assessed ex ante against a no-support counterfactual. Source: COBS 9B.1.1G/1.2G.
- TSM-704/705 Segment-level suitability is a binding RULE and delivery gate, judged
on the shared need and common characteristics, never on material assumptions. Source:
COBS 9B.4.20R.
- TSM-706 The firm must define the better position in measurable terms before
asserting it (firm method).
- TSM-707 Firm evidence method: quantified projection (baseline vs supported value,
cost of acting, horizon, detriment risk) with materiality thresholds — FIRM POLICY, the
FCA prescribed no methodology.
- TSM-708 Where any limb fails or no projection exists, better position is NOT
established and the suggestion is withheld; absence is an explicit false, never silence.
8. Charging and remuneration (TSM-802 — TSM-809)
- TSM-802 Where a charge is made: fair value assessment (PRIN 2A.4.2R via COBS
9B.4.2R(2)), disclosure in cash terms via a durable medium OR through a website, and
agreed with the client (the "before the service" timing is a firm-policy reading).
Source: COBS 9B.8.9R, PRIN 2A.
- TSM-803 Where no charge is made, remuneration must still be consistent with fair
value. Source: COBS 9B.8.7R.
- TSM-804 Third-party benefits prohibited outside the permitted exceptions (client
payments, cost-representative affiliate payments, minor non-monetary benefits,
compliant annuity brokerage referral fee). Source: COBS 9B.8.2R.
- TSM-809 Differential product cost through targeted support must be disclosed.
Source: COBS 9B.8.8R.
9. Disclosure and the article 55A statement (TSM-904 — TSM-910)
- TSM-904 Full COBS 9B.6 disclosure set required (service label, nature and
limitations, segment characteristics, designed-for-segment statement, product scope
limitations, assumptions, availability of advice, market comparison encouragement,
time-limited suitability), staged initial-contact vs point-of-delivery.
- TSM-905/906 The article 55A(4)/(5) statement — not comprehensive, not
individual-specific, specifying the group characteristics — delivered contemporaneously
with the recommendation.
- TSM-908 Disclosures must be tested for consumer understanding. Source: COBS 9B.6.9R.
- TSM-910 Durable medium at the point of delivery; where not practicable at the
time, as soon as reasonably practicable after (9B.6.18G fallback — the firm flag
asserts the arrangement exists). Source: COBS 9B.6.17R with 9B.6.18G.
10. Signposting when targeted support cannot help (TSM-1001 — TSM-1009)
- TSM-1001 Data sufficient but no segment confirmed, or no addressed situation →
signpost other support. Source: COBS 9B.7.
- TSM-1002 Consider and signpost other support including advice from other providers
(contra-indication, declined service). Source: COBS 9B.7.3G.
- TSM-1003 Problem debt routed to debt advice (firm policy precedence — consumer
protective).
- TSM-1004 Safeguarded benefits routed to regulated advice.
- TSM-1005 No alignment → MoneyHelper general guidance. Source: COBS 9B.4.19G(4)
(signpost guidance services where individuals cannot be served) with COBS 9B.7.3G.
- TSM-1006 Annuity suggestions must signpost the MoneyHelper annuity comparison.
Source: COBS 9B.4.28R(3).
- TSM-1007 COBS 19.7 pensions nudge (Pension Wise) continues to apply.
- TSM-1009 Vulnerability referral routed to specialist support.
11. Outcomes and the precedence ladder (TSM-1101 — TSM-1104)
- TSM-1101 Exactly one final outcome per case, selected by fact-table precedence
(lowest number wins); terminal default Request Further Data keeps the ladder total.
- TSM-1102 Candidate-outcome precedence projection.
- TSM-1103/1104 Delivery requires the FULL conjunction of explicit positive
determinations (perimeter, scope, initiation, marketing, selected suggestion,
suitability, better position, charging, disclosure, statement) — unknown never delivers.
- Precedence policy: consumer-protective and consumer-recoverable stops outrank firm-side
governance defects.
12. Supervisory file, MI, records (TSM-1201 — TSM-1211, TSM-1801/1802)
- TSM-1202 Segment design record for the aligned segment.
- TSM-1203/1206 Suitability and better-position basis recorded for every delivery.
- TSM-1204 Alignment record naming the confirmed segment; alignment gap records
naming each unconfirmed/unresolved characteristic.
- TSM-1205 Disclosure and article 55A statement record.
- TSM-1207 Charging and remuneration basis record.
- TSM-1208 Contra-indication finding and action taken.
- TSM-1209 Vulnerability assessment against the FG21/1 drivers.
- TSM-1210 Explicit clean records (design compliant, charging compliant, disclosure
complete) — audit-grade passes, not silent absence.
- TSM-1211 Retention: targeted support is expressly NOT a personal recommendation
(COBS 9B.2.6G(3), art 55A(2)); COBS 9B specifies no bespoke retention period, so the
SYSC 9 five-year MiFID-business retention is applied as a firm-policy reading;
telephone/face-to-face delivery engages recording rules. Records of disclosures incl.
the art 55A statement per COBS 9B.6.19G; records sufficient for FCA monitoring per
COBS 9B.10.12G.
- TSM-1801 Version stamp (policy parameter version + model version) so a historical
decision is replayable.
- TSM-1802 Record every gate that triggered, not only the reported outcome.
13. Governance and systems (TSM-1301)
- TSM-1301 COBS 9B.10.1R systems and controls; absence is a governance breach
blocking delivery (not a perimeter issue).
- TSM-1302 COBS 9B.10.9R regular, appropriately frequent review of the targeted
support processes including the suggestions: a firm with no recorded review frequency
is defective. COBS 9B.10.4G outcomes monitoring: a firm not monitoring outcomes of the
service carries a governance defect (Consumer Duty PRIN 2A monitoring).
- TSM-1303 Governance posture (root cause process, governing body reporting,
accountable senior manager under SYSC/SM&CR, vulnerable customer evaluation) recorded
in the supervisory file.
- TSM-1304 Data-protection posture (Article 6 lawful basis, separation of marketing
and service records, data-subject explanation of profiling) recorded in the supervisory
file per the FCA/ICO joint statement.
- TSM-1305 Equality Act: a segment characteristic engaging a protected characteristic
(age, health) must carry a recorded equality justification; absence is a design defect.
- TSM-1306 Third-party benefits marked annuity-referral-only (COBS 9B.8.4R) may only
be accepted on annuity cases; receipt on a non-annuity case is a charging defect.
- TSM-1307 Target market consistency (COBS 9B.4.24G(2)): a suggestion referencing a
product whose recorded target market does not include the selected segment is blocked.
- TSM-1308 Product governance posture: every targeted support firm is manufacturer
and distributor of the SERVICE and manufacturer and/or distributor of suggested
products; PRIN and PROD distributor rules apply (there is NO "PROD 8" targeted support
chapter — PROD was amended by FCA 2026/5 consequentially). Recorded in the supervisory
file.
- TSM-1309 Special category data (health/vulnerability disclosures) requires a UK
GDPR Article 9 condition per the FCA/ICO joint statement; a case processing a health
disclosure at a firm with no recorded Article 9 condition is blocked as a governance
defect.
- TSM-139 Complaints: targeted support is within DISP and FOS compulsory jurisdiction
from 6 April 2026; any FOS suitability assessment is based on the design of consumer
segments, not individual suitability; DISP 1 unchanged. Recorded in the supervisory
file on every decided case. Source: FCA/FOS joint statement, 11 Dec 2025.
- TSM-1212 Contributing evidence: every material derived finding carries a
contributing-evidence line with the actual figures, mirror-guarded on the finding it
narrates (COBS 9B.10.12G records posture).
14. Automated decision-making (TSM-1701 — TSM-1704)
- TSM-1701/1703 Automated decision status recorded (automated with human review vs
solely automated). DUAA 2025 replaced UK GDPR Article 22 with Articles 22A–22D (in
force 5 Feb 2026): a permissive safeguards regime (information, representations, human
intervention, contest — Art 22C). Whether a targeted support suggestion is a
"significant decision" is UNRESOLVED and ICO ADM guidance is in DRAFT (consultation
closed 29 May 2026), so the stance is firm policy.
- TSM-1704 Solely automated decisions are routed for human review (firm policy).
15. Aggregates and situation calculus (TSM-1401 — TSM-1407)
- TSM-1401 Under-saving: contribution rate below firm adequacy target.
- TSM-1402 Retirement proximity, access intent, income preference, tax bands.
- TSM-1403 Sustainable withdrawal rate (firm figure, not FCA).
- TSM-1404 Small pots identification, count and threshold.
- TSM-1405 Emergency buffer and excess cash (months × essential expenditure; floor).
- TSM-1406 Portfolio value, non-diversified concentration (zero-divisor and empty-set
guarded), portfolio minimum.
- TSM-1407 Ongoing charges, unwrapped holdings, ISA allowance use.
All numeric thresholds are FIRM POLICY facts on the Kesterly Targeted Support Policy
instance (the FCA publishes no thresholds for these situations) and are recalibrated as
data, never rules.
Direction 1 — rule to requirement to source
Layer 1 — Perimeter and permission
| Rule name (verbatim) |
TSM ID(s) |
Regulatory source |
| TSM-101 TSM-102 TSM-112 TSM-113 TSM-114 TSM-115 Perimeter cleared on positive determinations |
TSM-101, 102, 112, 113, 114, 115 (TSM-116 absorbed: positive-determination conjunction) |
RAO art 55A (SI 2026/74); COBS 9B.2.4G; COBS territorial application |
| TSM-101 Firm does not hold the targeted support permission |
TSM-101 |
RAO art 55A (SI 2026/74); FCA PS25/22 (Part 4A permission; art 53 permission insufficient) |
| TSM-102 Appointed representatives may not provide targeted support |
TSM-102 |
COBS 9B.2.4G verbatim; HMT did not extend the AR regulations |
| TSM-113 Client is not a natural person |
TSM-113 |
RAO art 55A (individual/retail consumer) |
| TSM-114 Trust based occupational scheme rights are not specified investments |
TSM-114 |
RAO specified-investment perimeter (arts 3, 82; no art-82 analogue for trust-based schemes) |
| TSM-115 Consumer is outside the territorial scope of COBS |
TSM-115 |
COBS territorial application |
| TSM-112 Case predates the 6 April 2026 regime commencement |
TSM-112 |
SI 2026/74 (in force 6 April 2026 for all purposes beyond rule-making) |
| TSM-103 Subject matter is a designated investment or structured deposit in COBS 9B scope |
TSM-103 |
COBS 9B.2 (designated investments incl. pensions, not pure protection) |
| TSM-104 Within article 55A but outside COBS 9B so the advising rules apply |
TSM-104 |
COBS 9B.2 / PERG |
| TSM-107 TSM-108 Client treated as retail and no individual suitability asserted |
TSM-107, 108 |
COBS 9B.3; RAO art 55A(4) |
Layer 2 — Initiation, consent and marketing
| Rule name (verbatim) |
TSM ID(s) |
Regulatory source |
| TSM-201 Initiation on an express client request |
TSM-201 |
COBS 9B.5.3R |
| TSM-201 Initiation on reasonable grounds that the client is in an addressed situation |
TSM-201 |
COBS 9B.5.3R |
| TSM-202 A service availability notice is not initiation |
TSM-202 |
COBS 9B.5.3R context (availability notice is not initiation of the service) |
| TSM-201 Firm initiated with no express request and no reasonable grounds |
TSM-201 |
COBS 9B.5.3R |
| TSM-201 Reasonable grounds claimed but no addressed situation identified |
TSM-201 |
COBS 9B.5.3R |
| TSM-205 Broadcast channel is not direct marketing so no consent is needed |
TSM-205 |
FCA/ICO joint statement 11 Dec 2025 (broadcast outside PECR direct-marketing rules) |
| TSM-205 Non electronic channels are outside the PECR electronic mail rules |
TSM-205 |
PECR reg 22 scope; FCA/ICO joint statement |
| TSM-204 TSM-132 Electronic mail with granular consent |
TSM-204, 132 |
PECR reg 22; UK GDPR consent standard; FCA/ICO joint statement |
| TSM-208 Standard PECR soft opt in for an existing customer |
TSM-208 |
PECR reg 22(3) |
| TSM-208 Workplace pension soft opt in route is pending legislation and is not relied on |
TSM-208 |
HMT consultation response (SI committed, NOT laid as of 30 Aug 2026); PECR reg 22 |
| TSM-207 Service and important messages are not direct marketing |
TSM-207 |
FCA/ICO joint statement (service messages) |
| TSM-206 Neutral awareness message permitted without marketing permission |
TSM-206 |
FCA/ICO joint statement (neutral factual messages) |
| TSM-204 Electronic mail suggestion without consent or soft opt in |
TSM-204 |
PECR reg 22; FCA/ICO joint statement |
| TSM-131 Consumer has objected to direct marketing and the channel is electronic mail |
TSM-131 |
UK GDPR absolute right to object; FCA/ICO joint statement |
| TSM-209 TSM-210 Cross regime record for the promotion and marketing tests |
TSM-209, 210 |
FCA/ICO joint statement; COBS 4 (financial promotion test recorded alongside PECR test) |
| TSM-203 Client elected not to receive a targeted support service |
TSM-203 |
COBS 9B.5.14R (final-rules change: opt-out of the SERVICE); Consumer Duty |
Layer 3 — Consumer data sufficiency and provenance
| Rule name (verbatim) |
TSM ID(s) |
Regulatory source |
| TSM-302 TSM-303 Data item is present and within its staleness window at the assessment date |
TSM-302, 303 |
COBS 9B.4.17R; COBS 9B.5.7R |
| TSM-303 Data item is present but beyond its staleness window at the assessment date |
TSM-303 |
COBS 9B.5.7R |
| TSM-303 COBS 9B.5.7R client verification restores reliance on a stale record |
TSM-303 |
COBS 9B.5.7R |
| TSM-304 Two current records give materially different numeric values |
TSM-304 |
COBS 9B.5.7R (contradiction resolved before a suggestion); firm method |
| TSM-304 Two current records give different text values |
TSM-304 |
COBS 9B.5.7R; firm method |
| TSM-1901 TSM-1902 Characteristic rests only on weak provenance |
TSM-1901, 1902 |
FCA good and poor practice 23 Mar 2026 (provenance asymmetry) |
| TSM-305 Record which provenance supported each characteristic |
TSM-305 |
COBS 9B.10.12G records (supervisory file) |
| TSM-301 Segment specifies no information set for alignment |
TSM-301 |
COBS 9B.4.17R |
| TSM-304 Record ordinals are duplicated or missing so contradiction detection is unreliable |
TSM-304 |
Firm method (record-integrity guard supporting 9B.5.7R) |
| TSM-304 Mirror each record ordinal as a per consumer string mark so distinct counting works |
TSM-304 |
Firm method (supporting 9B.5.7R) |
| TSM-304 A record integrity defect makes contradiction detection unreliable |
TSM-304 |
Firm method (supporting 9B.5.7R) |
Layer 4 — Aggregates and situation calculus
| Rule name (verbatim) |
TSM ID(s) |
Regulatory source |
| TSM-1404 Project each pension pot value onto the consumer |
TSM-1404 |
Firm policy (small-pots calculus; no FCA figure) |
| TSM-1406 Project each investment holding value onto the consumer |
TSM-1406 |
Firm policy (portfolio calculus) |
| TSM-1406 Project only non diversified holding values for the concentration test |
TSM-1406 |
Firm policy (concentration test, guarded) |
| TSM-1407 Project each holding ongoing charge onto the consumer |
TSM-1407 |
Firm policy / data derivation (charges) |
| TSM-412 Total pension provision uses the total not per pension features |
TSM-412 |
Segment design measure (register: total, not per-pot) |
| TSM-1406 Total portfolio value across all investment holdings |
TSM-1406 |
Firm policy (portfolio calculus) |
| TSM-1406 Largest non diversified single holding |
TSM-1406 |
Firm policy (concentration calculus) |
| TSM-1407 Highest ongoing charge across holdings |
TSM-1407 |
Firm policy / data derivation |
| TSM-1406 Concentration of the largest non diversified holding |
TSM-1406 |
Firm policy (zero-divisor and empty-set guarded) |
| TSM-1404 Identify each pot below the firm defined small pot ceiling |
TSM-1404 |
Firm policy (small pot ceiling) |
| TSM-1404 Count the small pots held |
TSM-1404 |
Firm policy |
| TSM-1405 Emergency buffer is monthly essential expenditure times the policy month count |
TSM-1405 |
Firm policy (buffer months) |
| TSM-1405 Excess cash is the cash balance less the emergency buffer |
TSM-1405 |
Firm policy |
| TSM-1402 Years remaining to the target retirement age |
TSM-1402 |
Firm policy / data derivation |
| TSM-1403 Withdrawal rate as a percentage of the drawdown fund |
TSM-1403 |
Firm policy (sustainable rate is a firm figure, not FCA) |
| TSM-411 Age band characteristics from policy held band edges |
TSM-411 |
Firm policy (band edges held as data) |
| TSM-1405 Excess cash above the emergency buffer and the policy floor |
TSM-1405 |
Firm policy (floor) |
Layer 5 — Derived characteristics, exclusions and explicit negatives
| Rule name (verbatim) |
TSM ID(s) |
Regulatory source |
| TSM-509 Emergency fund present as a CHARACTERISTIC never an assumption |
TSM-509 |
COBS 9B.4.11R (derived characteristic, never an assumption) |
| TSM-509 TSM-507 No emergency fund is an excluding characteristic |
TSM-509, 507 |
Segment design (financial resilience); COBS 9B.4.16R(1) |
| TSM-1902 Explicit negative for the no emergency fund exclusion |
TSM-1902 |
FCA good and poor practice (explicit negatives require the underlying record) |
| TSM-507 No problem debt recorded |
TSM-507 |
Segment design (financial resilience) |
| TSM-507 Problem debt is an indicator of low financial resilience |
TSM-507 |
Segment design (financial resilience) |
| TSM-1902 Explicit negative for the problem debt exclusion |
TSM-1902 |
FCA good and poor practice (provenance discipline) |
| TSM-317 Risk tolerance and capacity for loss bands both support market exposure |
TSM-317 |
COBS 9B.4.11R (client-stated, banded, never assumed); firm banding |
| TSM-317 No investment risk accepted |
TSM-317 |
COBS 9B.4.11R (client-stated); firm banding |
| TSM-317 No capacity to absorb any capital loss |
TSM-317 |
COBS 9B.4.11R (client-stated); firm banding |
| TSM-1902 Explicit negative for the capital loss exclusion |
TSM-1902 |
FCA good and poor practice (provenance discipline) |
| TSM-1406 Single holding concentration above the firm defined limit |
TSM-1406 |
Firm policy (concentration limit) |
| TSM-1406 Portfolio above the firm defined minimum value |
TSM-1406 |
Firm policy (portfolio minimum) |
| TSM-1407 Holds investments outside a tax wrapper |
TSM-1407 |
Data derivation (unwrapped holdings) |
| TSM-1407 ISA allowance not fully used this tax year |
TSM-1407 |
Data derivation (ISA allowance use) |
| TSM-1407 Holds a fund charging above the median |
TSM-1407 |
Firm policy (median charge benchmark) |
| TSM-1401 Contribution rate below the firm defined adequacy target |
TSM-1401 |
Firm policy (adequacy target) |
| TSM-105 Defined contribution benefits only with no safeguarded benefits |
TSM-105 |
COBS 9B.2.3R |
| TSM-105 Defined benefit safeguarded rights held |
TSM-105 |
COBS 9B.2.3R |
| TSM-106 Guaranteed annuity rate treated as safeguarded firm policy reading |
TSM-106 |
Firm policy reading (cf 90; Handbook glossary perimeter unresolved) |
| TSM-1907 Explicit negative for safeguarded benefits requires a complete benefit record |
TSM-1907 |
COBS 9B.2.3R fail-safe (firm policy cf 85) |
| TSM-1402 Within the firm defined retirement proximity window |
TSM-1402 |
Firm policy (proximity window) |
| TSM-1402 Client has stated an intention to take pension income |
TSM-1402 |
Client-stated data (access intent) |
| TSM-1402 Client has stated a guaranteed income preference never assumed |
TSM-1402 |
FCA good and poor practice (income-preference assumption is material — Example I); COBS 9B.4.11R |
| TSM-412 Total pension provision above the firm defined minimum |
TSM-412 |
Firm policy (provision minimum) |
| TSM-1403 Withdrawal rate above the firm defined sustainable rate |
TSM-1403 |
Firm policy (sustainable rate) |
| TSM-1403 Consumer is drawing an income from a pension fund |
TSM-1403 |
Data derivation |
| TSM-1404 Small pot count at or above the firm defined threshold |
TSM-1404 |
Firm policy (small-pot threshold) |
| TSM-508 Health issue affecting life expectancy from the vulnerability record |
TSM-508 |
FG21/1 (Health driver); segment design (decumulation exclusion) |
| TSM-1902 Explicit negative requires the vulnerability screen to have been run |
TSM-1902 |
FCA good and poor practice (provenance discipline); FG21/1 |
| TSM-512 Mental capacity not established firm policy exclusion |
TSM-512 |
Firm policy |
| TSM-1902 Explicit negative for the capacity exclusion |
TSM-1902 |
FCA good and poor practice (provenance discipline) |
| TSM-512 Below the firm defined minimum adult age |
TSM-512 |
Firm policy |
| TSM-1902 Explicit negative for the minimum age exclusion |
TSM-1902 |
FCA good and poor practice (provenance discipline) |
| TSM-512 Third party or attorney represented firm policy exclusion |
TSM-512 |
Firm policy |
| TSM-1402 Higher rate taxpayer as a BANDED characteristic |
TSM-1402 |
Firm policy (tax bands as banded characteristics) |
| TSM-1402 Basic rate taxpayer as a BANDED characteristic |
TSM-1402 |
Firm policy (tax bands) |
| TSM-1902 Explicit negative for the higher rate band exclusion |
TSM-1902 |
FCA good and poor practice (provenance discipline) |
Layer 6 — Segment design compliance
| Rule name (verbatim) |
TSM ID(s) |
Regulatory source |
| TSM-403 COBS 9B.4.16R(1) requires both including and excluding characteristics |
TSM-403 |
COBS 9B.4.16R(1) |
| TSM-408 A segment with no including characteristics would match every consumer |
TSM-408 |
COBS 9B.4.9R(1) |
| TSM-401 COBS 9B.4.4R requires a segment to be defined by reference to a situation |
TSM-401 |
COBS 9B.4.4R |
| TSM-402 COBS 9B.4.5R requires exactly one ready made suggestion per segment |
TSM-402 |
COBS 9B.4.5R |
| TSM-408 COBS 9B.4.9R(1) granularity floor for this situation |
TSM-408 |
COBS 9B.4.9R(1) |
| TSM-409 COBS 9B.4.9R(2) comprehensive consideration ceiling for this situation |
TSM-409 |
COBS 9B.4.9R(2) |
| TSM-311 COBS 9B.4.11R assumptions must be immaterial to suitability |
TSM-311 |
COBS 9B.4.11R with good and poor practice (materiality limb) |
| TSM-311 COBS 9B.4.11R assumptions must be referable to evidence |
TSM-311 |
COBS 9B.4.11R (verbatim limb) |
| TSM-413 Characteristic flagged poor practice for this situation by the FCA |
TSM-413 |
FCA good and poor practice 23 Mar 2026 |
| TSM-706 The firm must define what the better position is before asserting it |
TSM-706 |
Firm method (COBS 9B.1.1G evidencing expectation) |
| TSM-121 COBS 9B.4.16R(2) two limb relevance test |
TSM-121 |
COBS 9B.4.16R(2) |
| TSM-1305 A protected characteristic requires a recorded equality justification |
TSM-1305 |
Equality Act 2010 (age, health) |
| TSM-306 TSM-307 A segment may not require information that is not readily accessible |
TSM-306, 307 |
FCA good and poor practice 23 Mar 2026 (readily-accessible boundary) with COBS 9B.4.17R |
| TSM-414 Segment design not referable to evidence about the individuals it covers |
TSM-414 |
FCA good and poor practice; COBS 9B.4.11R evidence limb |
| TSM-1210 Explicit clean record for a segment with no design defect |
TSM-1210 |
Firm policy (audit-grade explicit clean records); COBS 9B.10.12G |
| TSM-403 A segment may only be used for alignment when it is design compliant |
TSM-403 |
COBS 9B.4 (design-defective segments never used for alignment) |
Layer 7 — Situation detection, alignment and qualification
| Rule name (verbatim) |
TSM ID(s) |
Regulatory source |
| TSM-401 Situation detected from a trigger characteristic the firm offers support for |
TSM-401 |
COBS 9B.4.4R |
| TSM-201 Situation taken from the client express request |
TSM-201 |
COBS 9B.5.3R |
| TSM-406 Compose a per case and per situation key for the single alignment tally |
TSM-406 |
COBS 9B.4.7R |
| TSM-406 Recover the situation from the composed key by rebuild and equality |
TSM-406 |
COBS 9B.4.7R |
| TSM-406 Attach each qualifying segment to its case and situation key |
TSM-406 |
COBS 9B.4.7R |
| TSM-406 COBS 9B.4.7R only one segment may be aligned within a situation |
TSM-406 |
COBS 9B.4.7R |
| TSM-404 Including characteristic not positively confirmed |
TSM-404 |
COBS 9B.5.5R |
| TSM-1902 Including characteristic rests only on weak provenance |
TSM-1902 |
FCA good and poor practice (weak provenance cannot establish an including characteristic) |
| TSM-405 A single excluding characteristic blocks alignment |
TSM-405 |
COBS 9B.4.16R(1) with 9B.5.5R |
| TSM-404 Excluding characteristic neither present nor explicitly absent |
TSM-404 |
COBS 9B.5.5R (exclusions positively resolved) |
| TSM-1204 Name each unconfirmed including characteristic for the supervisory file |
TSM-1204 |
COBS 9B.10.12G records |
| TSM-1204 Name each unresolved excluding characteristic for the supervisory file |
TSM-1204 |
COBS 9B.10.12G records |
| TSM-404 Candidate segment on a confirmed including set |
TSM-404 |
COBS 9B.5.5R |
| TSM-403 The consumer matches a segment that is not design compliant |
TSM-403 |
COBS 9B.4 (defective segment routed to governance) |
| TSM-404 TSM-405 Qualification requires a usable segment and fully resolved exclusions |
TSM-404, 405 |
COBS 9B.5.5R; 9B.4.16R(1) |
| TSM-302 Required information for this segment is missing or not current |
TSM-302 |
COBS 9B.4.17R (data sufficiency) |
| TSM-303 Stale alignment data not yet verified with the client |
TSM-303 |
COBS 9B.5.7R |
| TSM-304 Contradictory alignment data for this segment |
TSM-304 |
COBS 9B.5.7R; firm method |
| TSM-302 All required information for this segment is present and current |
TSM-302 |
COBS 9B.4.17R |
| TSM-404 Canonical confirmed alignment used by every downstream layer |
TSM-404 |
COBS 9B.5.5R |
| TSM-1905 Project the priority of each aligned situation onto the case |
TSM-1905 |
Firm policy (situation priority) |
| TSM-1905 Select the aligned segment in the highest priority situation |
TSM-1905 |
Firm policy (one suggestion per case) |
| TSM-1905 Record the situations deferred to a later interaction |
TSM-1905 |
Firm policy |
| Rule name (verbatim) |
TSM ID(s) |
Regulatory source |
| TSM-501 COBS 9B.5.11R contra indication from a readily accessible record |
TSM-501 |
COBS 9B.5.11R (with 9B.5.12G "readily accessible" framing) |
| TSM-123 Record the calibration of the contra indication gate |
TSM-123 |
COBS 9B.5.11R with 9B.5.12G (no data trawl expected) |
| TSM-503 FG21/1 driver present from the CRM record |
TSM-503 |
FG21/1 (Health, Life Events, Resilience, Capability) |
| TSM-503 FG21/1 driver present from the client own disclosure |
TSM-503 |
FG21/1 |
| TSM-504 Vulnerability indicator requiring referral from the CRM record |
TSM-504 |
COBS 9B.7.4G; FG21/1 |
| TSM-504 Vulnerability indicator requiring referral from the client disclosure |
TSM-504 |
COBS 9B.7.4G; FG21/1 |
| TSM-505 Vulnerability indicator requiring adjusted delivery from the CRM record |
TSM-505 |
FG21/1; COBS 9B.3.8G (adjusted delivery) |
| TSM-505 Vulnerability indicator requiring adjusted delivery from the client disclosure |
TSM-505 |
FG21/1; COBS 9B.3.8G |
| TSM-512 Third party or attorney represented routed to specialist support firm policy |
TSM-512 |
Firm policy |
| TSM-511 Volunteered information leads the firm to terminate the journey |
TSM-511 |
COBS 9B.5.11R ("is, or ought reasonably to be, aware") |
| TSM-511 Volunteered information requires clarification before realignment |
TSM-511 |
COBS 9B.5.11R |
| TSM-511 Volunteered information not yet routed by the firm |
TSM-511 |
COBS 9B.5.11R (unrouted volunteering blocks delivery) |
| TSM-511 Volunteered information handling record |
TSM-511 |
COBS 9B.5.11R; records posture |
| TSM-511 Volunteered information item detail |
TSM-511 |
COBS 9B.5.11R; records posture |
| TSM-514 Client requests a transaction inconsistent with the suggestion |
TSM-514 |
Firm policy (client-directed business outside targeted support) |
| TSM-514 Client directed transaction record |
TSM-514 |
Firm policy |
| TSM-510 COBS 9B.6.16G client is receiving or recently received advice |
TSM-510 |
COBS 9B.6.16G |
Layer 9 — Suggestion selection and product scope
| Rule name (verbatim) |
TSM ID(s) |
Regulatory source |
| TSM-601 The one suggestion specified for the selected segment |
TSM-601 |
COBS 9B.4.5R (single ready-made suggestion) |
| TSM-604 COBS 9B.4.42R prohibited investment category |
TSM-604 |
COBS 9B.4.42R |
| TSM-605 COBS 9B.4.43G complex illiquid or volatile product unsuitable for a limited information service |
TSM-605 |
COBS 9B.4.43G |
| TSM-606 COBS 9B.4.38R express consolidation recommendation prohibited |
TSM-606 |
COBS 9B.4.38R |
| TSM-607 COBS 9B.4.38R implied consolidation by transfer into an existing arrangement per the 9B.4.39G definition |
TSM-607 |
COBS 9B.4.38R with 9B.4.39G (TSM-608 permission encoded by the block shape — 9B.4.40G/41G) |
| TSM-607 COBS 9B.4.38R implied consolidation by transferring multiple arrangements per the 9B.4.39G definition |
TSM-607 |
COBS 9B.4.38R with 9B.4.39G |
| TSM-1307 COBS 9B.4.24G target market of the referenced product does not include the selected segment |
TSM-1307 |
COBS 9B.4.24G(2) |
| TSM-610 COBS 9B.4.28R annuity suggestion must not name a particular annuity |
TSM-610 |
COBS 9B.4.28R |
| TSM-610 COBS 9B.4.28R annuity suggestion must not include a quote |
TSM-610 |
COBS 9B.4.28R |
| TSM-610 COBS 9B.4.28R annuity suggestion must go no further than features |
TSM-610 |
COBS 9B.4.28R |
| TSM-616 COBS 9B.4.24G product costs must be evidenced |
TSM-616 |
COBS 9B.4.24G |
| TSM-616 COBS 9B.4.24G target market consistency must be evidenced |
TSM-616 |
COBS 9B.4.24G |
| TSM-616 COBS 9B.4.24G provider financial strength must be evidenced |
TSM-616 |
COBS 9B.4.24G |
| TSM-618 COBS 9B.10.6R manufacturer information on a significant product adaptation not reviewed by the firm |
TSM-618 |
COBS 9B.10.6R (distributor review duty) |
| TSM-111 Article 55A(3) presentation limb not satisfied |
TSM-111 |
RAO art 55A(3)(b)(iii) |
| TSM-601 Suggestion clears every product scope and evidencing block |
TSM-601 |
COBS 9B.4.5R with the 9B.4 product-scope rules |
| TSM-601 The single suggestion to be delivered for this case |
TSM-601 |
COBS 9B.4.5R |
Layer 10 — Segment suitability and better position
| Rule name (verbatim) |
TSM ID(s) |
Regulatory source |
| TSM-704 TSM-705 COBS 9B.4.20R segment level suitability on the shared need and characteristics |
TSM-704, 705 |
COBS 9B.4.20R (binding rule) |
| TSM-707 Materialise the projection on the segment so it can be counted |
TSM-707 |
Firm policy evidence method (FCA prescribed no methodology) |
| TSM-707 Gross improvement over the no support counterfactual |
TSM-707 |
Firm policy method; COBS 9B.1.1G counterfactual |
| TSM-707 Net improvement after the cost of acting |
TSM-707 |
Firm policy method |
| TSM-707 Net improvement as a percentage of the baseline |
TSM-707 |
Firm policy method |
| TSM-701 TSM-707 Better position established on a defined and evidenced projection |
TSM-701, 707 |
COBS 9B.1.1G/1.2G (guidance); firm policy method |
| TSM-708 Projection exists but the net improvement is immaterial |
TSM-708 |
Firm policy materiality threshold; COBS 9B.1.1G fail-safe |
| TSM-708 Projection exists but the percentage limb fails |
TSM-708 |
Firm policy method |
| TSM-708 Projection exists but the horizon is too short |
TSM-708 |
Firm policy method |
| TSM-708 Projection carries a detriment risk |
TSM-708 |
Firm policy method |
| TSM-708 No projection evidence exists at all |
TSM-708 |
COBS 9B.1.1G fail-safe (absence is explicit, never silence) |
| TSM-708 Explicit mark that better position evidence is absent |
TSM-708 |
COBS 9B.1.1G fail-safe |
| TSM-704 Project COBS 9B.4.20R suitability onto the case |
TSM-704 |
COBS 9B.4.20R |
| TSM-701 Project the better position determination onto the case |
TSM-701 |
COBS 9B.1.1G/1.2G |
| TSM-708 Project a failed better position determination onto the case |
TSM-708 |
COBS 9B.1.1G fail-safe; firm method |
Layer 11 — Charging, disclosure, governance and data-protection controls
| Rule name (verbatim) |
TSM ID(s) |
Regulatory source |
| TSM-804 COBS 9B.8.2R third party benefit outside the permitted exceptions |
TSM-804 |
COBS 9B.8.2R (exceptions 9B.8.3R/9B.8.4R) |
| TSM-802 PRIN 2A.4.2R fair value where a charge is made |
TSM-802 |
PRIN 2A.4.2R via COBS 9B.4.2R(2) |
| TSM-802 COBS 9B.8.9R charge must be disclosed in cash terms |
TSM-802 |
COBS 9B.8.9R |
| TSM-802 COBS 9B.8.9R charge disclosure must be in a durable medium |
TSM-802 |
COBS 9B.8.9R (durable medium OR website) |
| TSM-802 COBS 9B.8.9R charge must be agreed with the client before the service |
TSM-802 |
COBS 9B.8.9R (the "before" timing is a firm-policy reading) |
| TSM-803 COBS 9B.8.7R fair value where NO charge is made |
TSM-803 |
COBS 9B.8.7R |
| TSM-809 COBS 9B.8.8R differential product cost must be disclosed |
TSM-809 |
COBS 9B.8.8R |
| TSM-908 COBS 9B.6.9R disclosures must be tested for consumer understanding |
TSM-908 |
COBS 9B.6.9R |
| TSM-910 COBS 9B.6.17R durable medium at the point of delivery |
TSM-910 |
COBS 9B.6.17R with 9B.6.18G fallback |
| TSM-118 COBS 9B.1.3G duties and liability must not be excluded or restricted |
TSM-118 |
COBS 9B.1.3G; PRIN |
| TSM-1301 COBS 9B.10.1R systems and controls is a governance breach not a perimeter issue |
TSM-1301 |
COBS 9B.10.1R |
| TSM-1302 COBS 9B.10.4G outcomes of the service must be monitored |
TSM-1302 |
COBS 9B.10.4G; PRIN 2A monitoring |
| TSM-1302 COBS 9B.10.9R regular review of the targeted support processes |
TSM-1302 |
COBS 9B.10.9R |
| TSM-1306 COBS 9B.8.4R annuity referral benefit accepted outside an annuity case |
TSM-1306 |
COBS 9B.8.4R |
| TSM-1309 UK GDPR Article 9 condition required where health data is processed |
TSM-1309 |
UK GDPR Art 9; FCA/ICO joint statement |
| TSM-802 TSM-1210 Explicit clean record for charging and remuneration |
TSM-802, 1210 |
COBS 9B.8; firm policy (audit-grade clean records) |
| TSM-904 Required disclosure item not provided by the firm |
TSM-904 |
COBS 9B.6 disclosure set |
| TSM-904 TSM-1210 Explicit clean record for the disclosure set |
TSM-904, 1210 |
COBS 9B.6; firm policy (audit-grade clean records) |
| TSM-905 TSM-906 Article 55A(4) and (5) statement delivered with the recommendation |
TSM-905, 906 |
RAO art 55A(4)/(5) (contemporaneous statement) |
Layer 12 — Next steps, signposting and automated decision-making
| Rule name (verbatim) |
TSM ID(s) |
Regulatory source |
| TSM-1003 Problem debt routed to debt advice firm policy precedence |
TSM-1003 |
Firm policy precedence (consumer protective) |
| TSM-1004 Safeguarded benefits routed to regulated advice |
TSM-1004 |
Firm routing consistent with COBS 9B.7.3G |
| TSM-1007 COBS 19.7 pensions nudge continues to apply to a targeted support firm |
TSM-1007 |
COBS 19.7 (Pension Wise nudge) |
| TSM-1006 COBS 9B.4.28R(3) the one hard MoneyHelper rule inside COBS 9B |
TSM-1006 |
COBS 9B.4.28R(3) |
| TSM-613 COBS 9B.4.33R brokerage referral only after the interaction ends |
TSM-613 |
COBS 9B.4.33R (with 9B.4.35R sufficient range, 9B.4.36G) |
| TSM-1009 Vulnerability referral routed to specialist support |
TSM-1009 |
COBS 9B.7.4G; FG21/1 |
| TSM-1005 COBS 9B.4.19G(4) no alignment so signpost guidance services |
TSM-1005 |
COBS 9B.4.19G(4) with 9B.7.3G (MoneyHelper routing is firm policy) |
| TSM-1002 COBS 9B.7.3G consider and signpost other support including advice from others |
TSM-1002 |
COBS 9B.7.3G |
| TSM-1002 COBS 9B.7.3G contra indication routed to advice from other providers |
TSM-1002 |
COBS 9B.7.3G |
| TSM-510 COBS 9B.6.16G explain how targeted support differs from advice |
TSM-510 |
COBS 9B.6.16G |
| TSM-303 COBS 9B.5.7R verify possibly out of date information before confirming alignment |
TSM-303 |
COBS 9B.5.7R |
| TSM-302 Request the missing information |
TSM-302 |
COBS 9B.4.17R (data sufficiency next step) |
| TSM-403 Route a design defect to governance not to the consumer |
TSM-403 |
COBS 9B.4 (design compliance routed to governance) |
| TSM-612 COBS 9B.4.32R end the interaction after an annuity suggestion |
TSM-612 |
COBS 9B.4.32R |
| TSM-1905 Record deferred situations |
TSM-1905 |
Firm policy (situation priority) |
| TSM-910 COBS 9B.6.17R durable medium at delivery |
TSM-910 |
COBS 9B.6.17R |
| TSM-504 Vulnerability referral next step |
TSM-504 |
COBS 9B.7.4G; FG21/1 |
| TSM-1704 Automated decision routed for human review |
TSM-1704 |
Firm policy; DUAA 2025 / UK GDPR arts 22A–22D context |
| TSM-1701 Automated decision with an identified human involvement point |
TSM-1701 |
DUAA 2025 — UK GDPR arts 22A–22D |
| TSM-1701 Solely automated with no human involvement point |
TSM-1701 |
DUAA 2025 — UK GDPR arts 22A–22D ("solely automated" = no meaningful human involvement) |
| TSM-1704 Solely automated decisions are routed for human review firm policy |
TSM-1704 |
Firm policy ("significant decision" status unresolved; ICO guidance in draft) |
| TSM-138 Retirement income reporting classification |
TSM-138 |
FCA data collection / reporting expectations (PS25/22) |
| TSM-138 Non advised product sales data classification |
TSM-138 |
FCA data collection / reporting expectations |
| TSM-510 Advice distinction required but not confirmed by the client |
TSM-510 |
COBS 9B.6.16G |
Layer 13 — Stop gates and defect determinations
| Rule name (verbatim) |
TSM ID(s) |
Regulatory source |
| TSM-105 COBS 9B.2.3R absolute prohibition where safeguarded benefits are held |
TSM-105 |
COBS 9B.2.3R |
| TSM-1907 Safeguarded benefit status unknown so fail safe to the stop |
TSM-1907 |
COBS 9B.2.3R fail-safe (firm policy cf 85) |
| TSM-403 Matched only segments carrying a COBS 9B.4 design defect |
TSM-403 |
COBS 9B.4 |
| TSM-406 COBS 9B.4.7R more than one segment qualifies within a situation |
TSM-406 |
COBS 9B.4.7R |
| TSM-1301 COBS 9B.10.1R systems and controls absent |
TSM-1301 |
COBS 9B.10.1R |
| TSM-1302 Governance monitoring or review gap blocks delivery |
TSM-1302 |
COBS 9B.10.4G / 9B.10.9R; PRIN 2A |
| TSM-1309 Special category data processed without an Article 9 condition |
TSM-1309 |
UK GDPR Art 9; FCA/ICO joint statement |
| TSM-1306 Annuity referral benefit outside the permitted exception |
TSM-1306 |
COBS 9B.8.4R |
| TSM-1003 Problem debt takes precedence over investment oriented support firm policy |
TSM-1003 |
Firm policy precedence |
| TSM-504 COBS 9B.7.4G vulnerability may determine whether to provide support at all |
TSM-504 |
COBS 9B.7.4G; FG21/1 |
| TSM-501 COBS 9B.5.11R information indicates the suggestion may be unsuitable |
TSM-501 |
COBS 9B.5.11R |
| TSM-804 COBS 9B.8 charging or remuneration defect |
TSM-804 |
COBS 9B.8 |
| TSM-802 Charged delivery missing a required charging control |
TSM-802 |
COBS 9B.8.9R; PRIN 2A.4.2R |
| TSM-604 TSM-606 TSM-610 A product scope, consolidation or annuity block was raised |
TSM-604, 606, 610 |
COBS 9B.4.42R; 9B.4.38R; 9B.4.28R |
| TSM-302 Required alignment information is missing or not current |
TSM-302 |
COBS 9B.4.17R |
| TSM-303 Stale alignment data awaiting client verification |
TSM-303 |
COBS 9B.5.7R |
| TSM-304 Contradictory alignment data must be resolved first |
TSM-304 |
COBS 9B.5.7R; firm method |
| TSM-1001 Data sufficient but no segment could be confirmed |
TSM-1001 |
COBS 9B.7 |
| TSM-1001 Consumer is in no situation the firm addresses |
TSM-1001 |
COBS 9B.7 |
| TSM-904 A required COBS 9B.6 disclosure is not provided |
TSM-904 |
COBS 9B.6 |
| TSM-908 Disclosures not tested for consumer understanding |
TSM-908 |
COBS 9B.6.9R |
| TSM-910 Durable medium not provided at delivery |
TSM-910 |
COBS 9B.6.17R |
| TSM-118 A limitation disclosure must not disclaim liability |
TSM-118 |
COBS 9B.1.3G; PRIN |
| TSM-111 Article 55A statement absent so the article 53 carve out fails |
TSM-111 |
RAO art 55A(2)–(5) |
| TSM-704 COBS 9B.4.20R segment level suitability not affirmatively established |
TSM-704 |
COBS 9B.4.20R |
| TSM-701 TSM-708 Better position not established on the firm evidence method |
TSM-701, 708 |
COBS 9B.1.1G/1.2G; firm policy method |
| TSM-708 No better position determination could be made at all |
TSM-708 |
COBS 9B.1.1G fail-safe |
| TSM-510 Advice distinction not confirmed with the client |
TSM-510 |
COBS 9B.6.16G |
Layer 14 — Delivery conjunction and the precedence ladder
| Rule name (verbatim) |
TSM ID(s) |
Regulatory source |
| TSM-1104 TSM-1103 Full delivery conjunction on positive determinations only |
TSM-1104, 1103 |
Model architecture implementing the whole-chapter COBS 9B conjunction (unknown never delivers) |
| TSM-505 Delivery with adjusted delivery for a vulnerability indicator |
TSM-505 |
FG21/1; COBS 9B.3.8G |
| TSM-1102 Project the precedence of each candidate outcome onto the case |
TSM-1102 |
Model architecture / firm precedence policy |
| TSM-1101 The highest precedence reached is the lowest precedence number |
TSM-1101 |
Model architecture / firm precedence policy |
| TSM-1101 Exactly one final outcome, the highest precedence candidate |
TSM-1101 |
Model architecture / firm precedence policy |
| TSM-1101 Terminal default so the ladder is total |
TSM-1101 |
Model architecture (terminal default Request Further Data) |
Layer 15 — Supervisory file, records and MI
| Rule name (verbatim) |
TSM ID(s) |
Regulatory source |
| TSM-1801 Version stamp so a historical decision is replayable |
TSM-1801 |
Firm policy (replayability) |
| TSM-1202 Segment design record for the aligned segment |
TSM-1202 |
COBS 9B.10.12G records |
| TSM-1305 Equality justification record for the selected segment |
TSM-1305 |
Equality Act 2010 |
| TSM-1303 Governance posture record |
TSM-1303 |
SYSC/SM&CR; Consumer Duty (governance posture) |
| TSM-1304 Data protection posture record |
TSM-1304 |
FCA/ICO joint statement (Art 6 basis, record separation, profiling transparency) |
| TSM-139 Complaints and Financial Ombudsman record |
TSM-139 |
FCA/FOS joint statement 11 Dec 2025; DISP |
| TSM-1308 Product governance posture record |
TSM-1308 |
PRIN and PROD distributor rules (FCA 2026/5 consequentials; no "PROD 8") |
| TSM-311 Life expectancy assumption disclosed for the selected suggestion |
TSM-311 |
COBS 9B.4.11R; COBS 9B.6 (assumption disclosure) |
| TSM-1204 Alignment record naming the confirmed segment |
TSM-1204 |
COBS 9B.10.12G records |
| TSM-1204 Alignment gap record where alignment failed |
TSM-1204 |
COBS 9B.10.12G records |
| TSM-1203 TSM-1206 Suitability and better position basis for the delivered suggestion |
TSM-1203, 1206 |
COBS 9B.10.12G records |
| TSM-1208 Contra indication finding and the action taken |
TSM-1208 |
COBS 9B.10.12G records |
| TSM-1209 Vulnerability assessment against the FG21/1 drivers |
TSM-1209 |
FG21/1; COBS 9B.10.12G records |
| TSM-1207 Charging and remuneration basis |
TSM-1207 |
COBS 9B.10.12G records |
| TSM-1205 Disclosure and article 55A statement record |
TSM-1205 |
COBS 9B.6.19G |
| TSM-1701 TSM-1703 Automated decision making record |
TSM-1701, 1703 |
DUAA 2025 — UK GDPR arts 22A–22D; FCA/ICO joint statement |
| TSM-1802 Record every gate that triggered not only the reported outcome |
TSM-1802 |
Firm policy (audit completeness) |
| TSM-1211 Record retention and the MiFID personal recommendation characterisation |
TSM-1211 |
COBS 9B.2.6G(3); RAO art 55A(2) (NOT a personal recommendation); SYSC 9 five-year retention as a firm-policy reading; COBS 9B.6.19G / 9B.10.12G |
| TSM-137 Aggregable MI field for the FCA periodic data request |
TSM-137 |
FCA data collection expectations (PS25/22 first-year data) |
| TSM-137 MI field naming the suggestion actually delivered |
TSM-137 |
FCA data collection expectations |
| TSM-137 MI field recording an opt out |
TSM-137 |
FCA data collection expectations |
| TSM-137 MI field recording the access method suggested |
TSM-137 |
FCA data collection expectations |
| TSM-137 MI field recording each referral to guidance or advice |
TSM-137 |
FCA data collection expectations |
| TSM-137 MI field recording the fair value assessment status |
TSM-137 |
FCA data collection expectations |
Layer 16 — Evidence layer (contributing-evidence rules)
The six "Evidence …" rules implement TSM-1212 (every material derived finding carries a
contributing-evidence line with the actual figures, mirror-guarded on the finding it
narrates — COBS 9B.10.12G records posture):
| Rule name (verbatim) |
TSM ID(s) |
Regulatory source |
| Evidence Excess cash above the emergency buffer |
TSM-1212 |
COBS 9B.10.12G records posture |
| Evidence Single holding concentration above the firm limit |
TSM-1212 |
COBS 9B.10.12G records posture |
| Evidence Withdrawal rate above the sustainable rate |
TSM-1212 |
COBS 9B.10.12G records posture |
| Evidence Contribution below the adequacy target |
TSM-1212 |
COBS 9B.10.12G records posture |
| Evidence Multiple small pots held |
TSM-1212 |
COBS 9B.10.12G records posture |
| Evidence No indicator or defect found on a clean delivery |
TSM-1212 |
COBS 9B.10.12G records posture |
Direction 2 — source to requirements to rules
Each subsection is one verified source. Implementing rule names are verbatim; a
rule appears under every source that grounds one of its TSM IDs.
1. RAO article 55A (SI 2026/74, legislation.gov.uk)
Verified against the live source (made 28 Jan 2026; in force 6 Apr 2026 for
all purposes; art 55A(2) carve-out from art 53 confirmed verbatim).
| TSM ID |
Requirement (condensed) |
Implementing rule name(s) |
| TSM-101 |
Part 4A permission for the new art 55A activity required; art 53 permission does not authorise it |
TSM-101 TSM-102 TSM-112 TSM-113 TSM-114 TSM-115 Perimeter cleared on positive determinations; TSM-101 Firm does not hold the targeted support permission |
| TSM-108 |
No individual suitability determination made or asserted (art 55A(4)) |
TSM-107 TSM-108 Client treated as retail and no individual suitability asserted |
| TSM-111 |
Presentation limb ("suitable for the individual on the basis of being in the group") and the art 55A(4)/(5) statement, or the art 53 carve-out fails |
TSM-111 Article 55A(3) presentation limb not satisfied; TSM-111 Article 55A statement absent so the article 53 carve out fails |
| TSM-112 |
Regime applies from 6 April 2026 |
TSM-112 Case predates the 6 April 2026 regime commencement; (perimeter conjunction rule) |
| TSM-114 |
Trust-based occupational scheme rights outside the specified-investment perimeter |
TSM-114 Trust based occupational scheme rights are not specified investments; (perimeter conjunction rule) |
| TSM-905/906 |
Statement: not comprehensive, not individual-specific, specifying the group characteristics, delivered at the same time as the recommendation (art 55A(5)) |
TSM-905 TSM-906 Article 55A(4) and (5) statement delivered with the recommendation |
2. COBS 9B.1 — purpose and better position
| TSM ID |
Requirement (condensed) |
Implementing rule name(s) |
| TSM-701 |
Reasonable grounds that segment members would be in a better position than without the support (GUIDANCE, ex ante, no-support counterfactual) |
TSM-701 TSM-707 Better position established on a defined and evidenced projection; TSM-701 Project the better position determination onto the case; TSM-701 TSM-708 Better position not established on the firm evidence method |
| TSM-706 |
Better position defined in measurable terms before it is asserted (firm method) |
TSM-706 The firm must define what the better position is before asserting it |
| TSM-707 |
Quantified projection evidence method — baseline vs supported value, cost of acting, horizon, detriment risk, materiality thresholds (FIRM POLICY; FCA prescribed no methodology) |
TSM-707 Materialise the projection on the segment so it can be counted; TSM-707 Gross improvement over the no support counterfactual; TSM-707 Net improvement after the cost of acting; TSM-707 Net improvement as a percentage of the baseline; TSM-701 TSM-707 Better position established on a defined and evidenced projection |
| TSM-708 |
Any limb fails or no projection → better position NOT established, suggestion withheld; absence is an explicit false |
TSM-708 Projection exists but the net improvement is immaterial; TSM-708 Projection exists but the percentage limb fails; TSM-708 Projection exists but the horizon is too short; TSM-708 Projection carries a detriment risk; TSM-708 No projection evidence exists at all; TSM-708 Explicit mark that better position evidence is absent; TSM-708 Project a failed better position determination onto the case; TSM-701 TSM-708 Better position not established on the firm evidence method; TSM-708 No better position determination could be made at all |
3. COBS 9B.2 — application
| TSM ID |
Requirement (condensed) |
Implementing rule name(s) |
| TSM-102 |
ARs may not provide targeted support (9B.2.4G verbatim) |
TSM-102 Appointed representatives may not provide targeted support; (perimeter conjunction rule) |
| TSM-103 |
COBS 9B applies to designated investments (incl. pensions), not pure protection |
TSM-103 Subject matter is a designated investment or structured deposit in COBS 9B scope |
| TSM-104 |
Within art 55A but outside COBS 9B → advising rules apply |
TSM-104 Within article 55A but outside COBS 9B so the advising rules apply |
| TSM-105 |
Absolute prohibition where the consumer holds safeguarded benefits (9B.2.3R) |
TSM-105 Defined contribution benefits only with no safeguarded benefits; TSM-105 Defined benefit safeguarded rights held; TSM-105 COBS 9B.2.3R absolute prohibition where safeguarded benefits are held |
| TSM-106 |
Guaranteed annuity rate treated as a safeguarded indicator (FIRM POLICY reading, cf 90) |
TSM-106 Guaranteed annuity rate treated as safeguarded firm policy reading |
| TSM-113 |
Client must be a natural person |
TSM-113 Client is not a natural person; (perimeter conjunction rule) |
| TSM-115 |
Territorial scope: UK consumers |
TSM-115 Consumer is outside the territorial scope of COBS; (perimeter conjunction rule) |
| TSM-1907 |
Unknown safeguarded status fails safe to the 9B.2.3R stop (cf 85) |
TSM-1907 Explicit negative for safeguarded benefits requires a complete benefit record; TSM-1907 Safeguarded benefit status unknown so fail safe to the stop |
| TSM-1211 |
9B.2.6G(3): targeted support is expressly NOT a personal recommendation (retention treated under 9B.10 below) |
TSM-1211 Record retention and the MiFID personal recommendation characterisation |
4. COBS 9B.3 — general
| TSM ID |
Requirement (condensed) |
Implementing rule name(s) |
| TSM-107 |
Client treated as retail regardless of categorisation; COBS 9/9A suitability disapplied |
TSM-107 TSM-108 Client treated as retail and no individual suitability asserted |
5. COBS 9B.4 — design of targeted support
| TSM ID |
Requirement (condensed) |
Implementing rule name(s) |
| TSM-121 |
Two-limb relevance test for every common characteristic (9B.4.16R(2)) |
TSM-121 COBS 9B.4.16R(2) two limb relevance test |
| TSM-301 |
Segment must specify the information required to establish alignment (9B.4.17R) |
TSM-301 Segment specifies no information set for alignment |
| TSM-311 |
Assumptions reasonable, referable to evidence, immaterial to suitability (9B.4.11R; materiality limb via good/poor practice) |
TSM-311 COBS 9B.4.11R assumptions must be immaterial to suitability; TSM-311 COBS 9B.4.11R assumptions must be referable to evidence; TSM-311 Life expectancy assumption disclosed for the selected suggestion |
| TSM-401 |
Segment defined by reference to a situation involving a shared financial support need (9B.4.4R) |
TSM-401 COBS 9B.4.4R requires a segment to be defined by reference to a situation; TSM-401 Situation detected from a trigger characteristic the firm offers support for |
| TSM-402 |
Exactly one ready-made suggestion per segment (9B.4.5R) |
TSM-402 COBS 9B.4.5R requires exactly one ready made suggestion per segment |
| TSM-403 |
Design-defective segments never used for alignment; routed to governance |
TSM-403 COBS 9B.4.16R(1) requires both including and excluding characteristics; TSM-403 A segment may only be used for alignment when it is design compliant; TSM-403 The consumer matches a segment that is not design compliant; TSM-403 Route a design defect to governance not to the consumer; TSM-403 Matched only segments carrying a COBS 9B.4 design defect |
| TSM-404 (partial — delivery limb under 9B.5) |
Including characteristics positively confirmed |
TSM-404 Candidate segment on a confirmed including set; TSM-404 Canonical confirmed alignment used by every downstream layer (full list under COBS 9B.5) |
| TSM-406 |
Only one segment may align within a situation (9B.4.7R) |
TSM-406 Compose a per case and per situation key for the single alignment tally; TSM-406 Recover the situation from the composed key by rebuild and equality; TSM-406 Attach each qualifying segment to its case and situation key; TSM-406 COBS 9B.4.7R only one segment may be aligned within a situation; TSM-406 COBS 9B.4.7R more than one segment qualifies within a situation |
| TSM-408 |
Granularity floor (9B.4.9R(1)) |
TSM-408 A segment with no including characteristics would match every consumer; TSM-408 COBS 9B.4.9R(1) granularity floor for this situation |
| TSM-409 |
Comprehensive-consideration ceiling (9B.4.9R(2)) |
TSM-409 COBS 9B.4.9R(2) comprehensive consideration ceiling for this situation |
| TSM-413 |
FCA-flagged poor-practice characteristics are design defects (also under source 12) |
TSM-413 Characteristic flagged poor practice for this situation by the FCA |
| TSM-414 |
Segment design must be referable to evidence about the covered individuals (no register entry — see Coverage; also under source 12) |
TSM-414 Segment design not referable to evidence about the individuals it covers |
| TSM-601 |
The single suggestion delivered is the one specified for the selected segment (9B.4.5R) |
TSM-601 The one suggestion specified for the selected segment; TSM-601 Suggestion clears every product scope and evidencing block; TSM-601 The single suggestion to be delivered for this case |
| TSM-604 |
No prohibited investment categories (9B.4.42R) |
TSM-604 COBS 9B.4.42R prohibited investment category; TSM-604 TSM-606 TSM-610 A product scope, consolidation or annuity block was raised |
| TSM-605 |
Complex/illiquid/volatile products unlikely suitable (9B.4.43G); packaged products and sell recommendations not prevented |
TSM-605 COBS 9B.4.43G complex illiquid or volatile product unsuitable for a limited information service |
| TSM-606 |
Express consolidation recommendation prohibited (9B.4.38R) |
TSM-606 COBS 9B.4.38R express consolidation recommendation prohibited; TSM-604 TSM-606 TSM-610 A product scope, consolidation or annuity block was raised |
| TSM-607 |
Implied consolidation prohibited (9B.4.38R with the 9B.4.39G definition) |
TSM-607 COBS 9B.4.38R implied consolidation by transfer into an existing arrangement per the 9B.4.39G definition; TSM-607 COBS 9B.4.38R implied consolidation by transferring multiple arrangements per the 9B.4.39G definition |
| TSM-608 |
Single-pot transfer to a NEW provider is NOT consolidation (9B.4.40G); multi-pot support permitted (9B.4.41G) — ABSORBED: encoded as the deliberate shape of the TSM-606/607 blocks (both flags false raises no block) |
(no dedicated rule — permission by block shape) |
| TSM-610 |
Annuity suggestions: features only, no particular annuity, no quote (9B.4.28R) |
TSM-610 COBS 9B.4.28R annuity suggestion must not name a particular annuity; TSM-610 COBS 9B.4.28R annuity suggestion must not include a quote; TSM-610 COBS 9B.4.28R annuity suggestion must go no further than features; TSM-604 TSM-606 TSM-610 A product scope, consolidation or annuity block was raised |
| TSM-612 |
Interaction ends after an annuity suggestion (9B.4.32R) |
TSM-612 COBS 9B.4.32R end the interaction after an annuity suggestion |
| TSM-613 |
Brokerage referral only after the interaction ends, MoneyHelper opportunity, no quote, sufficient range (9B.4.33R/35R/36G) |
TSM-613 COBS 9B.4.33R brokerage referral only after the interaction ends |
| TSM-616 |
Product costs, target market consistency and provider financial strength evidenced (9B.4.24G) |
TSM-616 COBS 9B.4.24G product costs must be evidenced; TSM-616 COBS 9B.4.24G target market consistency must be evidenced; TSM-616 COBS 9B.4.24G provider financial strength must be evidenced |
| TSM-704/705 |
Segment-level suitability is a binding RULE and delivery gate (9B.4.20R) |
TSM-704 TSM-705 COBS 9B.4.20R segment level suitability on the shared need and characteristics; TSM-704 Project COBS 9B.4.20R suitability onto the case; TSM-704 COBS 9B.4.20R segment level suitability not affirmatively established |
| TSM-1006 |
Annuity suggestions signpost the MoneyHelper comparison (9B.4.28R(3)) |
TSM-1006 COBS 9B.4.28R(3) the one hard MoneyHelper rule inside COBS 9B |
| TSM-1307 |
Target market of the referenced product must include the selected segment (9B.4.24G(2)) |
TSM-1307 COBS 9B.4.24G target market of the referenced product does not include the selected segment |
6. COBS 9B.5 — delivery
| TSM ID |
Requirement (condensed) |
Implementing rule name(s) |
| TSM-201 |
Initiation only on express request or reasonable grounds of an addressed situation (9B.5.3R) |
TSM-201 Initiation on an express client request; TSM-201 Initiation on reasonable grounds that the client is in an addressed situation; TSM-201 Firm initiated with no express request and no reasonable grounds; TSM-201 Reasonable grounds claimed but no addressed situation identified; TSM-201 Situation taken from the client express request |
| TSM-202 |
Service availability notice is not initiation |
TSM-202 A service availability notice is not initiation |
| TSM-203 |
Client election not to receive the SERVICE is an absolute stop (9B.5.14R, final-rules change) |
TSM-203 Client elected not to receive a targeted support service |
| TSM-302 |
Required information missing/not current → no alignment; data request issued |
TSM-302 TSM-303 Data item is present and within its staleness window at the assessment date; TSM-302 Required information for this segment is missing or not current; TSM-302 All required information for this segment is present and current; TSM-302 Request the missing information; TSM-302 Required alignment information is missing or not current |
| TSM-303 |
Possibly out-of-date data verified with the client before alignment (9B.5.7R) |
TSM-303 Data item is present but beyond its staleness window at the assessment date; TSM-303 Stale alignment data not yet verified with the client; TSM-303 COBS 9B.5.7R verify possibly out of date information before confirming alignment; TSM-303 Stale alignment data awaiting client verification; TSM-303 COBS 9B.5.7R client verification restores reliance on a stale record |
| TSM-304 |
Contradictory current records resolved before a suggestion; ordinal integrity guarded |
TSM-304 Two current records give materially different numeric values; TSM-304 Two current records give different text values; TSM-304 Record ordinals are duplicated or missing so contradiction detection is unreliable; TSM-304 Mirror each record ordinal as a per consumer string mark so distinct counting works; TSM-304 A record integrity defect makes contradiction detection unreliable; TSM-304 Contradictory alignment data for this segment; TSM-304 Contradictory alignment data must be resolved first |
| TSM-404 |
Including characteristics positively confirmed; exclusions positively resolved (9B.5.5R) |
TSM-404 Including characteristic not positively confirmed; TSM-404 Excluding characteristic neither present nor explicitly absent; TSM-404 Candidate segment on a confirmed including set; TSM-404 TSM-405 Qualification requires a usable segment and fully resolved exclusions; TSM-404 Canonical confirmed alignment used by every downstream layer |
| TSM-405 |
A single excluding characteristic held blocks alignment (9B.4.16R(1) with 9B.5.5R) |
TSM-405 A single excluding characteristic blocks alignment; TSM-404 TSM-405 Qualification requires a usable segment and fully resolved exclusions |
| TSM-501 |
Readily accessible information indicating unsuitability prohibits delivery (9B.5.11R) |
TSM-501 COBS 9B.5.11R contra indication from a readily accessible record; TSM-501 COBS 9B.5.11R information indicates the suggestion may be unsuitable |
| TSM-511 |
Volunteered information is information the firm IS aware of; must be routed, unrouted volunteering blocks delivery (9B.5.11R) |
TSM-511 Volunteered information leads the firm to terminate the journey; TSM-511 Volunteered information requires clarification before realignment; TSM-511 Volunteered information not yet routed by the firm; TSM-511 Volunteered information handling record; TSM-511 Volunteered information item detail |
| TSM-514 |
Inconsistent transaction request processed outside targeted support as client-directed business (firm policy) |
TSM-514 Client requests a transaction inconsistent with the suggestion; TSM-514 Client directed transaction record |
| TSM-1902 |
Explicit negatives require the underlying record; weak provenance never establishes an including characteristic (positive-resolution discipline supporting 9B.5.5R; provenance strength under source 12) |
TSM-1902 Explicit negative for the no emergency fund exclusion; TSM-1902 Explicit negative for the problem debt exclusion; TSM-1902 Explicit negative for the capital loss exclusion; TSM-1902 Explicit negative requires the vulnerability screen to have been run; TSM-1902 Explicit negative for the capacity exclusion; TSM-1902 Explicit negative for the minimum age exclusion; TSM-1902 Explicit negative for the higher rate band exclusion; TSM-1902 Including characteristic rests only on weak provenance; TSM-1901 TSM-1902 Characteristic rests only on weak provenance |
7. COBS 9B.6 — disclosure
| TSM ID |
Requirement (condensed) |
Implementing rule name(s) |
| TSM-510 |
Concurrent/recent advice is not a bar; the advice distinction must be explained and confirmed (9B.6.16G) |
TSM-510 COBS 9B.6.16G client is receiving or recently received advice; TSM-510 COBS 9B.6.16G explain how targeted support differs from advice; TSM-510 Advice distinction required but not confirmed by the client; TSM-510 Advice distinction not confirmed with the client |
| TSM-904 |
Full COBS 9B.6 disclosure set, staged initial contact vs point of delivery |
TSM-904 Required disclosure item not provided by the firm; TSM-904 TSM-1210 Explicit clean record for the disclosure set; TSM-904 A required COBS 9B.6 disclosure is not provided |
| TSM-905/906 |
Article 55A(4)/(5) statement delivered contemporaneously (COBS 9B.6 delivery context; statutory text under source 1) |
TSM-905 TSM-906 Article 55A(4) and (5) statement delivered with the recommendation |
| TSM-908 |
Disclosures tested for consumer understanding (9B.6.9R) |
TSM-908 COBS 9B.6.9R disclosures must be tested for consumer understanding; TSM-908 Disclosures not tested for consumer understanding |
| TSM-910 |
Durable medium at the point of delivery; 9B.6.18G as-soon-as-practicable fallback (9B.6.17R) |
TSM-910 COBS 9B.6.17R durable medium at the point of delivery; TSM-910 COBS 9B.6.17R durable medium at delivery; TSM-910 Durable medium not provided at delivery |
| TSM-1205 |
Records of disclosures incl. the art 55A statement (9B.6.19G) |
TSM-1205 Disclosure and article 55A statement record |
8. COBS 9B.7 — unable to provide a suggestion
| TSM ID |
Requirement (condensed) |
Implementing rule name(s) |
| TSM-504 |
Referral-severity vulnerability stops the service; vulnerability may determine whether to provide support at all (9B.7.4G with FG21/1) |
TSM-504 Vulnerability indicator requiring referral from the CRM record; TSM-504 Vulnerability indicator requiring referral from the client disclosure; TSM-504 COBS 9B.7.4G vulnerability may determine whether to provide support at all; TSM-504 Vulnerability referral next step |
| TSM-1001 |
Data sufficient but no segment confirmed, or no addressed situation → signpost other support |
TSM-1001 Data sufficient but no segment could be confirmed; TSM-1001 Consumer is in no situation the firm addresses |
| TSM-1002 |
Consider and signpost other support incl. advice from other providers (9B.7.3G) |
TSM-1002 COBS 9B.7.3G consider and signpost other support including advice from others; TSM-1002 COBS 9B.7.3G contra indication routed to advice from other providers |
| TSM-1004 |
Safeguarded benefits routed to regulated advice (firm routing consistent with 9B.7.3G) |
TSM-1004 Safeguarded benefits routed to regulated advice |
| TSM-1005 |
No alignment → signpost guidance services / MoneyHelper (9B.4.19G(4) with 9B.7.3G; routing choice firm policy) |
TSM-1005 COBS 9B.4.19G(4) no alignment so signpost guidance services |
| TSM-1009 |
Vulnerability referral routed to specialist support |
TSM-1009 Vulnerability referral routed to specialist support |
9. COBS 9B.8 — charging and remuneration
| TSM ID |
Requirement (condensed) |
Implementing rule name(s) |
| TSM-802 |
Where a charge is made: fair value (PRIN 2A.4.2R via 9B.4.2R(2)); cash-terms disclosure; durable medium or website; agreed with the client ("before" timing is firm policy) (9B.8.9R) |
TSM-802 PRIN 2A.4.2R fair value where a charge is made; TSM-802 COBS 9B.8.9R charge must be disclosed in cash terms; TSM-802 COBS 9B.8.9R charge disclosure must be in a durable medium; TSM-802 COBS 9B.8.9R charge must be agreed with the client before the service; TSM-802 TSM-1210 Explicit clean record for charging and remuneration; TSM-802 Charged delivery missing a required charging control |
| TSM-803 |
No charge → remuneration still consistent with fair value (9B.8.7R) |
TSM-803 COBS 9B.8.7R fair value where NO charge is made |
| TSM-804 |
Third-party benefits prohibited outside the permitted exceptions (9B.8.2R with 9B.8.3R/4R) |
TSM-804 COBS 9B.8.2R third party benefit outside the permitted exceptions; TSM-804 COBS 9B.8 charging or remuneration defect |
| TSM-809 |
Differential product cost disclosed (9B.8.8R) |
TSM-809 COBS 9B.8.8R differential product cost must be disclosed |
| TSM-1306 |
Annuity-referral-only benefits (9B.8.4R) accepted only on annuity cases |
TSM-1306 COBS 9B.8.4R annuity referral benefit accepted outside an annuity case; TSM-1306 Annuity referral benefit outside the permitted exception |
10. COBS 9B.10 — systems, controls and records
| TSM ID |
Requirement (condensed) |
Implementing rule name(s) |
| TSM-618 |
Review manufacturer information on significant product adaptations before further suggestions (9B.10.6R distributor review duty) |
TSM-618 COBS 9B.10.6R manufacturer information on a significant product adaptation not reviewed by the firm |
| TSM-1301 |
Systems and controls for design and delivery compliance; absence is a governance breach blocking delivery (9B.10.1R) |
TSM-1301 COBS 9B.10.1R systems and controls is a governance breach not a perimeter issue; TSM-1301 COBS 9B.10.1R systems and controls absent |
| TSM-1302 |
Regular review of processes (9B.10.9R) and outcomes monitoring (9B.10.4G) |
TSM-1302 COBS 9B.10.4G outcomes of the service must be monitored; TSM-1302 COBS 9B.10.9R regular review of the targeted support processes; TSM-1302 Governance monitoring or review gap blocks delivery |
| TSM-1303 |
Governance posture (root cause, governing body, SM&CR accountable manager, vulnerable customer evaluation) recorded |
TSM-1303 Governance posture record |
| TSM-1802 |
Every gate that triggered is recorded, not only the reported outcome (firm audit policy on the 9B.10.12G posture) |
TSM-1802 Record every gate that triggered not only the reported outcome |
| TSM-1801 |
Version stamp so a historical decision is replayable (firm policy) |
TSM-1801 Version stamp so a historical decision is replayable |
| TSM-1210 |
Explicit clean records — audit-grade passes, not silent absence |
TSM-1210 Explicit clean record for a segment with no design defect; TSM-802 TSM-1210 Explicit clean record for charging and remuneration; TSM-904 TSM-1210 Explicit clean record for the disclosure set |
| TSM-1211 |
Retention: NOT a personal recommendation (9B.2.6G(3), art 55A(2)); SYSC 9 five-year retention as firm-policy reading; disclosure records per 9B.6.19G; records for FCA monitoring per 9B.10.12G |
TSM-1211 Record retention and the MiFID personal recommendation characterisation |
| TSM-305 |
Provenance supporting each characteristic recorded (supervisory file) |
TSM-305 Record which provenance supported each characteristic |
| TSM-1202 |
Segment design record for the aligned segment |
TSM-1202 Segment design record for the aligned segment |
| TSM-1203/1206 |
Suitability and better-position basis recorded for every delivery |
TSM-1203 TSM-1206 Suitability and better position basis for the delivered suggestion |
| TSM-1204 |
Alignment record naming the confirmed segment; gap records naming each unconfirmed/unresolved characteristic |
TSM-1204 Name each unconfirmed including characteristic for the supervisory file; TSM-1204 Name each unresolved excluding characteristic for the supervisory file; TSM-1204 Alignment record naming the confirmed segment; TSM-1204 Alignment gap record where alignment failed |
| TSM-1207 |
Charging and remuneration basis record |
TSM-1207 Charging and remuneration basis |
| TSM-1208 |
Contra-indication finding and action taken |
TSM-1208 Contra indication finding and the action taken |
| TSM-1209 |
Vulnerability assessment against the FG21/1 drivers |
TSM-1209 Vulnerability assessment against the FG21/1 drivers |
| TSM-1212 |
Contributing-evidence lines with actual figures on every material derived finding (9B.10.12G records posture) |
Evidence Excess cash above the emergency buffer; Evidence Single holding concentration above the firm limit; Evidence Withdrawal rate above the sustainable rate; Evidence Contribution below the adequacy target; Evidence Multiple small pots held; Evidence No indicator or defect found on a clean delivery |
11. COBS 19.7 — pensions guidance nudge
| TSM ID |
Requirement (condensed) |
Implementing rule name(s) |
| TSM-1007 |
The COBS 19.7 Pension Wise nudge continues to apply to a targeted support firm |
TSM-1007 COBS 19.7 pensions nudge continues to apply to a targeted support firm |
12. FCA good and poor practice — designing consumer segments (23 March 2026)
Verified against the live source (credit-card history held elsewhere and
detailed transaction analysis are NOT "readily accessible"; assuming flexible-over-fixed
income preference is unreasonable and material to suitability).
| TSM ID |
Requirement (condensed) |
Implementing rule name(s) |
| TSM-306/307 |
Not-readily-accessible data (credit-card history, transaction pattern analysis) can never be required for alignment |
TSM-306 TSM-307 A segment may not require information that is not readily accessible (design-defect rule added in the final build iteration and verified live) |
| TSM-413 |
Characteristics flagged poor practice for a situation are design defects when used |
TSM-413 Characteristic flagged poor practice for this situation by the FCA |
| TSM-1901/1902 |
Provenance strength asymmetry: weak provenance (firm inference, third-party feed) may support an excluding characteristic but never establishes an including one; explicit negatives require the underlying record |
TSM-1901 TSM-1902 Characteristic rests only on weak provenance; TSM-1902 Including characteristic rests only on weak provenance; the seven "TSM-1902 Explicit negative …" rules (no emergency fund; problem debt; capital loss; vulnerability screen; capacity; minimum age; higher rate band) |
| TSM-414 |
Segment design referable to evidence about the individuals it covers |
TSM-414 Segment design not referable to evidence about the individuals it covers |
13. FCA/ICO joint statement (11 Dec 2025) + PECR reg 22 + UK GDPR
Verified against the live statements.
| TSM ID |
Requirement (condensed) |
Implementing rule name(s) |
| TSM-131 |
Objection to direct marketing blocks an electronic-mail suggestion (absolute right to object) |
TSM-131 Consumer has objected to direct marketing and the channel is electronic mail |
| TSM-132 |
Granular, unbundled consent record (UK GDPR consent standard) |
TSM-204 TSM-132 Electronic mail with granular consent |
| TSM-204 |
Electronic-mail suggestion is direct marketing: PECR reg 22 consent or soft opt-in required |
TSM-204 TSM-132 Electronic mail with granular consent; TSM-204 Electronic mail suggestion without consent or soft opt in |
| TSM-205 |
Broadcast and non-electronic-mail channels outside the PECR electronic mail rule |
TSM-205 Broadcast channel is not direct marketing so no consent is needed; TSM-205 Non electronic channels are outside the PECR electronic mail rules |
| TSM-206 |
Neutral factual awareness message permitted without marketing permission; cannot carry a suggestion |
TSM-206 Neutral awareness message permitted without marketing permission |
| TSM-207 |
Service messages are not direct marketing |
TSM-207 Service and important messages are not direct marketing |
| TSM-208 |
Standard reg 22(3) soft opt-in available; the workplace pension soft opt-in SI has NOT been laid as of 30 Aug 2026 — route recorded as pending legislation, never relied on |
TSM-208 Standard PECR soft opt in for an existing customer; TSM-208 Workplace pension soft opt in route is pending legislation and is not relied on |
| TSM-209/210 |
Cross-regime record: PECR direct-marketing test and COBS 4 financial-promotion test both recorded |
TSM-209 TSM-210 Cross regime record for the promotion and marketing tests |
| TSM-1304 |
Data-protection posture (Art 6 lawful basis, marketing/service record separation, profiling transparency) recorded |
TSM-1304 Data protection posture record |
| TSM-1309 |
Special category data requires a UK GDPR Article 9 condition; absence blocks the case |
TSM-1309 UK GDPR Article 9 condition required where health data is processed; TSM-1309 Special category data processed without an Article 9 condition |
| TSM-1701/1703 |
Automated decision status recorded under DUAA 2025 / UK GDPR arts 22A–22D ("significant decision" status unresolved; ICO guidance in draft) |
TSM-1701 Automated decision with an identified human involvement point; TSM-1701 Solely automated with no human involvement point; TSM-1701 TSM-1703 Automated decision making record |
| TSM-1704 |
Solely automated decisions routed for human review (firm policy) |
TSM-1704 Automated decision routed for human review; TSM-1704 Solely automated decisions are routed for human review firm policy |
14. FCA/FOS joint statement (11 Dec 2025) + DISP
Verified against the live statement (FOS suitability assessment "based
on the design of consumer segments, rather than at an individual level"; DISP 1 unchanged).
| TSM ID |
Requirement (condensed) |
Implementing rule name(s) |
| TSM-139 |
Targeted support within DISP and FOS compulsory jurisdiction from 6 Apr 2026; FOS assessment segment-design-based; recorded on every decided case |
TSM-139 Complaints and Financial Ombudsman record |
| TSM-123/501 |
Contra-indication gate calibration (no data trawl expected — 9B.5.11R/12G) is consistent with the FOS segment-design basis of review (the research file notes this reading is an inference from the Handbook, not a statement by the joint statement itself) |
TSM-123 Record the calibration of the contra indication gate; TSM-501 COBS 9B.5.11R contra indication from a readily accessible record; TSM-501 COBS 9B.5.11R information indicates the suggestion may be unsuitable |
15. FG21/1 — fair treatment of vulnerable customers
| TSM ID |
Requirement (condensed) |
Implementing rule name(s) |
| TSM-503 |
Four vulnerability drivers (Health, Life Events, Resilience, Capability) detected from CRM or client disclosure |
TSM-503 FG21/1 driver present from the CRM record; TSM-503 FG21/1 driver present from the client own disclosure |
| TSM-504 |
Referral-severity indicators stop the service and route to specialist support |
TSM-504 Vulnerability indicator requiring referral from the CRM record; TSM-504 Vulnerability indicator requiring referral from the client disclosure; TSM-504 COBS 9B.7.4G vulnerability may determine whether to provide support at all; TSM-504 Vulnerability referral next step |
| TSM-505 |
Adjusted-delivery indicators deliver with adjustments |
TSM-505 Vulnerability indicator requiring adjusted delivery from the CRM record; TSM-505 Vulnerability indicator requiring adjusted delivery from the client disclosure; TSM-505 Delivery with adjusted delivery for a vulnerability indicator |
| TSM-508 |
Significant health issue affecting life expectancy excludes decumulation segments |
TSM-508 Health issue affecting life expectancy from the vulnerability record |
| TSM-512 |
Protective firm-policy exclusions (capacity, minimum age, third-party representation) applied alongside the vulnerability screen |
TSM-512 Mental capacity not established firm policy exclusion; TSM-512 Below the firm defined minimum adult age; TSM-512 Third party or attorney represented firm policy exclusion; TSM-512 Third party or attorney represented routed to specialist support firm policy |
16. PRIN 2A — Consumer Duty
| TSM ID |
Requirement (condensed) |
Implementing rule name(s) |
| TSM-118 |
Duties and liability to the client not excluded or restricted |
TSM-118 COBS 9B.1.3G duties and liability must not be excluded or restricted; TSM-118 A limitation disclosure must not disclaim liability |
| TSM-802 |
Fair value assessment where a charge is made (PRIN 2A.4.2R via COBS 9B.4.2R(2)) |
TSM-802 PRIN 2A.4.2R fair value where a charge is made (full charging family under source 9) |
| TSM-803 |
Remuneration consistent with fair value where no charge is made |
TSM-803 COBS 9B.8.7R fair value where NO charge is made |
| TSM-1302 |
Outcomes monitoring (PRIN 2A monitoring behind COBS 9B.10.4G) |
TSM-1302 COBS 9B.10.4G outcomes of the service must be monitored; TSM-1302 Governance monitoring or review gap blocks delivery |
| TSM-1308 |
Product governance: firm is manufacturer/distributor of the service and of suggested products; PRIN and PROD distributor rules (no "PROD 8" chapter) |
TSM-1308 Product governance posture record |
17. FCA data collection expectations (PS25/22 first-year data)
| TSM ID |
Requirement (condensed) |
Implementing rule name(s) |
| TSM-137 |
Aggregable MI fields: outcome, suggestion delivered, opt-outs, access method, referrals, fair value status |
TSM-137 Aggregable MI field for the FCA periodic data request; TSM-137 MI field naming the suggestion actually delivered; TSM-137 MI field recording an opt out; TSM-137 MI field recording the access method suggested; TSM-137 MI field recording each referral to guidance or advice; TSM-137 MI field recording the fair value assessment status |
| TSM-138 |
Reporting classification: retirement income vs non-advised product sales |
TSM-138 Retirement income reporting classification; TSM-138 Non advised product sales data classification |
Every row here is a threshold or calibration the FCA has not prescribed; all numeric values
are FIRM POLICY facts on the Kesterly Targeted Support Policy instance, recalibrated as
data, never rules.
| TSM ID |
Requirement (condensed) |
Implementing rule name(s) |
| TSM-106 |
Guaranteed annuity rate treated as a safeguarded-benefit indicator (cf 90; glossary perimeter unresolved) |
TSM-106 Guaranteed annuity rate treated as safeguarded firm policy reading |
| TSM-512 |
Capacity-not-established, minimum-adult-age and third-party-representation exclusions |
TSM-512 Mental capacity not established firm policy exclusion; TSM-512 Below the firm defined minimum adult age; TSM-512 Third party or attorney represented firm policy exclusion; TSM-512 Third party or attorney represented routed to specialist support firm policy |
| TSM-514 |
Inconsistent transaction requests processed as client-directed business |
TSM-514 Client requests a transaction inconsistent with the suggestion; TSM-514 Client directed transaction record |
| TSM-707 (method) |
Quantified better-position projection method and materiality thresholds |
TSM-707 Materialise the projection on the segment so it can be counted; TSM-707 Gross improvement over the no support counterfactual; TSM-707 Net improvement after the cost of acting; TSM-707 Net improvement as a percentage of the baseline; TSM-701 TSM-707 Better position established on a defined and evidenced projection |
| TSM-1003 |
Problem-debt-first routing precedence (consumer protective) |
TSM-1003 Problem debt routed to debt advice firm policy precedence; TSM-1003 Problem debt takes precedence over investment oriented support firm policy |
| TSM-1005 (routing) |
MoneyHelper as the general-guidance signpost destination |
TSM-1005 COBS 9B.4.19G(4) no alignment so signpost guidance services |
| TSM-1704 |
Solely automated decisions routed for human review |
TSM-1704 Automated decision routed for human review; TSM-1704 Solely automated decisions are routed for human review firm policy |
| TSM-1905 |
Situation priority selecting one aligned situation per case; the rest deferred and recorded |
TSM-1905 Project the priority of each aligned situation onto the case; TSM-1905 Select the aligned segment in the highest priority situation; TSM-1905 Record the situations deferred to a later interaction; TSM-1905 Record deferred situations |
| TSM-411, 412 |
Age band edges held as policy data; pension-provision minimum on the total |
TSM-411 Age band characteristics from policy held band edges; TSM-412 Total pension provision uses the total not per pension features; TSM-412 Total pension provision above the firm defined minimum |
| TSM-1401–1407 (all numeric policy facts) |
Adequacy target; proximity window and tax bands; sustainable withdrawal rate; small-pot ceiling/threshold; emergency buffer months and floor; concentration limit and portfolio minimum; charge benchmarks |
All Layer 4 aggregate rules and the firm-threshold characteristic rules in Layer 5 (TSM-1401 Contribution rate below the firm defined adequacy target; TSM-1402 Within the firm defined retirement proximity window; TSM-1403 Withdrawal rate above the firm defined sustainable rate; TSM-1404 Small pot count at or above the firm defined threshold; TSM-1405 Excess cash above the emergency buffer and the policy floor; TSM-1406 Single holding concentration above the firm defined limit; TSM-1406 Portfolio above the firm defined minimum value; TSM-1407 Holds a fund charging above the median; and their supporting projections/aggregations) |
| TSM-1907 (cf 85) |
Fail-safe certainty on unknown safeguarded status |
TSM-1907 Explicit negative for safeguarded benefits requires a complete benefit record; TSM-1907 Safeguarded benefit status unknown so fail safe to the stop |
| TSM-1801/1802 |
Replayable version stamp; every triggered gate recorded |
TSM-1801 Version stamp so a historical decision is replayable; TSM-1802 Record every gate that triggered not only the reported outcome |
Other grounding not enumerated above. TSM-1305 (Equality Act 2010 justification for
protected characteristics — TSM-1305 A protected characteristic requires a recorded equality
justification; TSM-1305 Equality justification record for the selected segment); TSM-507/509
(financial-resilience excluding characteristics and the emergency-fund derived
characteristic — segment design on the COBS 9B.4.16R(1)/9B.4.11R base); TSM-317 (client-stated
banded risk/capacity, never assumed — 9B.4.11R); TSM-1101/1102/1103/1104 (single-outcome
precedence ladder and full delivery conjunction — model architecture implementing the
whole-chapter COBS 9B conjunction with a consumer-protective precedence policy, terminal
default keeping the ladder total).
Coverage assertions
(a) Register → rules. The register (the first section of this document) contains
138 distinct TSM IDs. 135 of them appear verbatim in at least one rule name, and
TSM-1212 is implemented by the six "Evidence …" rules (which use the Evidence naming
convention rather than a TSM prefix) — 136 implemented by named rules. The two register
IDs that do NOT appear in any rule name are both absorbed by design, not gaps:
- TSM-116 — the register itself states it is covered within the
TSM-101/102 rules; the positive-determination discipline is the perimeter conjunction rule
"TSM-101 TSM-102 TSM-112 TSM-113 TSM-114 TSM-115 Perimeter cleared on positive
determinations" (unknown never places a case inside the perimeter).
- TSM-608 — the 9B.4.40G/41G permission (single-pot transfer to a
new provider is not consolidation; multi-pot support permitted) is encoded as the
deliberate shape of the TSM-606/607 consolidation blocks — the blocks fire only on the
9B.4.39G shapes, so both flags false raises no block. There is intentionally no rule to
name, because a permission expressed as the absence of a block has no firing rule.
(b) Rules → register. Every TSM ID carried by a rule name exists in the register
above. There are no orphan rule IDs.
Totals. 280 distinct TSM-prefixed rule names (each occurring exactly once in
graph.xml — no duplicated rule names or rule families) plus 6 "Evidence …"
rules = 286 rules mapped; 138 register IDs, of which 136 are implemented by named
rules and 2 are absorbed by design (TSM-116 in the perimeter conjunction, TSM-608 as the
deliberate shape of the consolidation blocks). No orphan rule IDs remain.