You have spent twenty-five years building a portfolio and a habit of asking who is accountable when something goes wrong. A robo-advisor asks you to hand over the same money to a questionnaire and an algorithm, then accept that the accountability sits with you. That is the trade. It is not automatically a bad one, but it needs to be priced, tested, and documented before you commit a six-figure ISA or a seven-figure pension to it.
This is the fourth decision moment in the pre-retirement sequence I write about: auditing the adviser relationship, timing the stop-work date, decumulation and risk psychology, tax-aware wrapper decisions, and the family paperwork. A robo-advisor sits inside the first and third of those. It changes who you can call, what you can evidence, and what happens when markets fall 20% in the year you planned to stop working.
What a robo-advisor actually is, and what it is not
A robo-advisor is a regulated investment service that builds and manages a portfolio from your answers to an online risk questionnaire, usually through a platform, with fees taken as a percentage of assets. In the UK, the main names include Vanguard Investor, Nutmeg (owned by J.P. Morgan), Wealthify, Moneyfarm, and InvestEngine. Some are discretionary fund managers; some are advisory; some are execution-only with a model portfolio bolted on. The distinction matters because it decides whether you have a right to complain about suitability, not just about execution.
What it is not: a fiduciary. The UK does not use that term in the way US readers expect. A firm can be independent, restricted, or execution-only. Only independent advisers must consider the whole market. A robo-advisor is typically restricted to its own funds or a short panel. That is not a scandal. It is a business model. But if you want someone to blame, you need to know which regulatory category you are dealing with before you sign, not after.
Check the firm on the FCA Register. Look for the permissions: advising on investments, arranging deals, managing investments. Look at the status: authorised, appointed representative, or in liquidation. Look at the date permissions were granted. A firm authorised in 2019 with a clean record is a different proposition from one authorised last month with a change of control pending. The register is free and takes four minutes. Do it before you read the marketing.
The five tests that separate a useful robo-advisor from an expensive tracker
1. The suitability report, or its absence
If the service is advisory or discretionary, you should receive a suitability report. Read it as a legal document, not a brochure. It should state your objectives, your attitude to risk, your capacity for loss, the recommended portfolio, and the charges. If it does not mention capacity for loss, it is incomplete. If it recommends 80% equities to a 58-year-old planning to stop work at 62 and draw 4% a year, ask what happens in a 30% drawdown. The report should answer that.
If the service is execution-only, you will get a risk questionnaire and a key information document. That is the whole accountability chain. You chose the portfolio. The firm executed it. If you want someone to blame, you are the someone. That is not a reason to avoid it. It is a reason to keep your own records.
2. The fee, expressed in pounds not percentages
A 0.25% platform fee on £400,000 is £1,000 a year. A 0.75% managed fee is £3,000. Add fund ongoing charges of 0.15% to 0.35% and you are at £3,600 to £4,400 a year before any advice charge. Over ten years, assuming flat markets, that is £36,000 to £44,000. Markets are not flat, but the arithmetic is the point. Percentages hide the number that leaves your account.
Compare that with a single global tracker at 0.15% all-in on a cheap platform: £600 a year on £400,000. The gap is the price of the questionnaire, the rebalancing, the tax wrappers, and the phone line. Decide whether you are buying those things or just the brand.
3. The rebalancing and tax logic
Ask how the service rebalances. Inside an ISA or SIPP, rebalancing is free of capital gains tax. In a general investment account, it is not. A robo-advisor that rebalances across all accounts without regard to the wrapper is creating tax events you did not ask for. The better services rebalance inside wrappers first and use new contributions to correct drift in taxable accounts. Ask the question directly. If the answer is vague, assume the worst.
Also ask about asset location. If you hold bonds and equities, the bonds belong in the ISA or SIPP where interest is sheltered, and the equities belong in the general account where capital gains can be managed. Most robo-advisors do not do this. Some do. It is worth 0.2% to 0.4% a year in tax terms for a £500,000 portfolio. That is real money.
4. The drawdown capability
Accumulation is easy. Decumulation is where robo-advisors are weakest. Ask three questions. Can you set a regular withdrawal? Can you specify which wrapper the withdrawal comes from? Can you see the projected depletion date under different return assumptions? If the answer to any of those is no, the service is an accumulation tool, not a retirement tool. You will need to move the money or build a spreadsheet alongside it.
This is the point where the robo-advisor meets the decumulation decision moment. A 4% withdrawal rate on a 60/40 portfolio has a reasonable historical success rate over 30 years, but the sequence of returns in the first five years matters more than the average. A robo-advisor that cannot model a bad first five years is not helping you plan. It is helping you invest.
5. The complaint route and the compensation limit
If the firm fails, the Financial Services Compensation Scheme covers investments up to £85,000 per person per firm. That is the limit. If you hold £400,000 with one robo-advisor and it goes bust, you are exposed above £85,000. The assets should be ring-fenced in custody, but ring-fencing is a legal argument, not a guarantee. Spreading across two providers is cheap insurance. It also gives you a comparison point.
If you have a complaint, the route is: the firm’s internal complaints process, then the Financial Ombudsman Service. The FOS can award up to £430,000 for complaints about acts or omissions after 1 April 2019. That is a real accountability mechanism, but it only works if you have evidence of what you were told. Keep the suitability report, the questionnaire answers, and the annual reviews. If the firm cannot produce them, that is itself a finding.
The uncomfortable truth about blame
You want someone to blame because blame is a proxy for recourse. If the money falls, you want a person, a firm, a regulator, a process that says: this was not your fault, and here is the remedy. A robo-advisor removes most of that. It replaces it with a documented process and a complaints route. That is not nothing. It is just not the same thing.
The trade is explicit. You give up the relationship and the discretionary judgement. You gain lower cost, consistent process, and no sales pressure. For a £300,000 portfolio, the cost difference between a 1% adviser and a 0.3% robo-advisor is £2,100 a year. Over twenty years, that is £42,000 before growth. That is the price of the person to blame. Some people should pay it. Some should not. The decision is yours, but it should be made with the number in front of you.
There is a middle path. Use a robo-advisor for the accumulation phase and a fixed-fee adviser for the decumulation plan. Or use an adviser for the one-off suitability report and a robo-advisor for execution. The FCA’s guidance on investment platforms sets out what you should expect. The MoneyHelper investing basics page is a useful sanity check on risk and charges. Neither will tell you which firm to use. Both will help you ask better questions.
How to run the evaluation in one afternoon
Pick three services. For each, do the following.
Step 1. Check the FCA Register. Note the permissions, the status, and the date. Note the firm reference number.
Step 2. Find the fee schedule. Write down the platform fee, the managed fee, the fund ongoing charge, the dealing fee, the withdrawal fee, and the transfer-out fee. Add them up on a £400,000 portfolio. Write the annual pound figure.
Step 3. Request a sample suitability report or key information document. Read the risk section. Look for capacity for loss. Look for the withdrawal modelling.
Step 4. Ask the three drawdown questions by email. Keep the reply.
Step 5. Check the FSCS limit and decide whether you need two providers.
Step 6. Write one paragraph explaining, to yourself, who is accountable if the portfolio falls 25% in year one. If the answer is ‘me’, accept that and move on. If the answer is ‘them’, you need an adviser, not a robo-advisor.
This is the same discipline I set out in the question you should be asking years before you retire. The question is not ‘which product’. It is ‘who decides, who documents, and who pays when it goes wrong’.
Where this fits in the five decision moments
The robo-advisor decision touches the adviser audit, because it changes the fee and the accountability. It touches decumulation, because the withdrawal mechanics are where most services are thin. It touches tax wrappers, because asset location and rebalancing inside ISAs and SIPPs are worth real money. It touches the family paperwork only indirectly, but the expression of wish form and the lasting power of attorney still need to name someone. If the robo-advisor is the only counterparty, the paperwork still has to work.
Two dates to keep in view. From April 2027, unused pension funds will be subject to inheritance tax on the death of the member, subject to the legislation as drafted. From April 2028, the normal minimum pension age rises to 57. Neither changes the robo-advisor decision directly, but both change the wrapper logic around it. If you are 55 now and planning to access a SIPP at 57, the robo-advisor needs to support that. If you are 60 and planning to leave the pension untouched for inheritance reasons, the robo-advisor needs to support that too. Ask before you transfer.
FAQ
Is a robo-advisor cheaper than a financial adviser?
Almost always, on a like-for-like portfolio. A typical robo-advisor charges 0.2% to 0.75% a year plus fund charges. An adviser charges 0.5% to 1% plus fund charges, often with a minimum fee. On £400,000, the gap is £1,200 to £3,200 a year. The question is whether the adviser’s suitability report, tax planning, and decumulation modelling are worth that. For some people they are. For others, the robo-advisor plus a one-off fixed-fee review is the better structure.
Can I complain about a robo-advisor?
Yes. If the firm is authorised by the FCA, you can complain to the firm and then to the Financial Ombudsman Service if you are unhappy with the response. The FOS can award up to £430,000 for complaints about acts or omissions after 1 April 2019. The limit is lower for earlier complaints. You need evidence of what you were told, so keep the suitability report and the questionnaire answers.
What happens if the robo-advisor goes bust?
Your assets should be held by a third-party custodian, separate from the firm’s own money. If the firm fails, the assets should be transferable. If there is a shortfall, the Financial Services Compensation Scheme covers up to £85,000 per person per firm. Above that, you are relying on the custody arrangements and the legal process. Spreading across two providers reduces the concentration risk.
Do robo-advisors handle drawdown well?
Some do, many do not. The key features are regular withdrawals, wrapper-specific withdrawals, and depletion modelling under different return scenarios. If the service cannot show you a projected balance under a bad first five years, it is an accumulation tool. You can still use it, but you will need to manage the withdrawal plan yourself or with an adviser.
Should I move my final salary pension to a robo-advisor?
Almost certainly not without regulated advice. Defined benefit transfers above £30,000 require advice from a pension transfer specialist. A robo-advisor will not provide that. The decision is about guaranteed income versus flexibility, and the numbers are specific to your scheme. This is one area where the person to blame is worth paying for.
The next step
Pick one robo-advisor you are considering. Run the six steps above. Write the annual pound cost on a £400,000 portfolio. Write the answer to the accountability question. If the cost is under £1,500 and the accountability answer is ‘me, with a documented process’, the robo-advisor is a reasonable choice. If the cost is over £3,000 and the accountability answer is ‘them’, you are paying adviser prices for a robo-advisor service. That is the trade to avoid.
If you want to go deeper on the decumulation side, the next article in this sequence covers the withdrawal order and the sequence-of-returns problem. That is where the robo-advisor decision either holds up or falls apart.