The FSA has held secret discussions with stakeholders about delaying the Retail Distribution Review (RDR) for at least one year.
It has held several meetings with the Association of IFAs (AIFA), the most recent being last week, after the trade body argued the dual pressures of the review and the economic environment would "drive good firms out of business".
However, so far the regulator says it remains committed to its current timescale, which demands all RDR recommendations are met by the end of 2012.
In its RDR feedback statement, published in November, the FSA announced increased capital and qualification requirements for firms and proposed splitting the advice market into 'independent' and 'sales' advisers.
Additionally, it outlawed all provider influence over remuneration and the changes, combined, will force hundreds of firms to switch business models.
"We have suggested to the regulator they need to review the deadline in light of the market conditions," says Chris Cummings, AIFA director general.
"By all accounts, 2009 is not going to be a good year and, as it stands, the FSA will drive good firms out of business. The RDR must be about consumers being better off; that is far more important than any arbitrary deadline. We think it's time for a bit less action and a bit more direction."
Cummings says AIFA is not calling for a "blanket" delay, arguing there may be "some elements" of the review which could meet their current deadline while others are put back.
"At the moment there is a 2012 limit for pretty much everything," he says. "That may have been OK during the good times, but things have changed."
Jim Reeve, chief executive of Positive Solutions, says it can take up to six years for an adviser to change business model.
"I really do think, with the economic environment and the scale of change required, it would be sensible to extend the deadline," he says. "Obviously it can't be put off forever, but the FSA must consider what would give people a better chance of implementing these changes successfully."
Fay Goddard, chief executive of the Personal Finance Society (PFS), describes 2012 as a "tight" deadline and says advisers are not being helped by a lack of clarity on which exams will be RDR compliant.
"If advisers are even to consider [meeting the RDR's qualifications remit] they are going to find it very difficult," she says.
The FSA says it is pressing ahead with implementation as planned. "The timetable we set out remains the case," a spokesman says. "But discussions with stakeholders, including trade bodies, remain ongoing."IFAonline
To promote 'long-term investment'
Switching 'hard and expensive'
Smaller funds still packing a punch
To drive progress