AI at work, by industry · Advisers, brokers, lenders, insurers, compliance staff and managers in regulated firms
AI in financial services: the Consumer Duty, accountability and the FCA's approach
No new AI rulebook does not mean no rules. What the existing ones ask when a tool touches a customer.
- 2modules
- 1.5CPD hours
- 90guided minutes
- Freeto study
This course is new. You could be the first to finish it.
Start the course, free Create a free account to save progress
About this course
The Financial Conduct Authority has said it does not plan to introduce extra regulations for AI and will rely on its existing frameworks. Firms sometimes hear that as freedom. It is the opposite: the Consumer Duty, the Senior Managers and Certification Regime and the rules on systems and controls already apply to whatever a firm does with a tool.
The ground is moving. In January 2026 the Treasury Committee recommended that the FCA give comprehensive and practical guidance on how its consumer protection and accountability rules apply to AI by the end of 2026. In July 2026 the FCA published the Mills Review of AI in retail financial services, with seven recommendations, the first of which is to look at general purpose AI tools that give advice-like outputs outside the regulatory perimeter.
This course sets out what the existing rules ask today: the four Consumer Duty outcomes applied to AI, who is accountable, and what a firm needs before a tool is allowed to affect a customer.
What you will be able to do
- State the FCA's approach to AI and what it relies on
- Apply the four Consumer Duty outcomes to a use of AI
- Explain where accountability sits under the Senior Managers and Certification Regime
- Describe the safeguards for solely automated decisions about customers
- Recognise the risk to customers in vulnerable circumstances
- Tell general information from a personal recommendation when a tool is involved
- List what a firm needs in place before a tool affects a customer
- Say what the Mills Review recommended and what is expected next
Modules
Assessment and certificate
Knowledge check after each module and a final assessment at 80 per cent, with unlimited attempts.
A digital certificate, issued the moment you have passed and paid, showing 1.5 CPD hours with a verification code. It evidences knowledge of how existing financial services regulation applies to AI. It is not a regulated qualification, it is not regulatory or financial advice, and it is not endorsed by the Financial Conduct Authority. Whether it counts towards your own CPD requirement is for you and your firm to judge.
Questions
Has the FCA written rules for AI?
No. Its stated position is that it does not plan to introduce extra regulations for AI and will rely on existing frameworks, principally the Consumer Duty and the Senior Managers and Certification Regime. The Treasury Committee has recommended it publish practical guidance by the end of 2026.
Who is accountable if an AI tool gives a customer a poor outcome?
The firm, and the senior manager responsible for the area. Accountability under the Senior Managers and Certification Regime does not transfer to a supplier, and outsourcing a function does not outsource the responsibility for it.
Can a tool decide whether someone gets a loan?
It can, with safeguards. Since 5 February 2026 a solely automated decision with a significant effect is permitted on ordinary personal data if the person is told, and can make representations, obtain human intervention and contest it. The Consumer Duty and the Equality Act apply to the outcome.
What is the Mills Review?
A review of AI in retail financial services commissioned by the FCA, launched in January 2026 and published on 6 July 2026. It made seven recommendations looking ahead to 2030. They are recommendations, not rules.