AI at work, by profession
The FCA's approach to AI: how the Consumer Duty and senior manager accountability apply
The Financial Conduct Authority has said it does not plan extra regulations for AI. This is what the existing rules ask when a tool touches a customer.
Checked against the published sources on 2 October 2026.
The short answer
The FCA describes its approach as principles based and focused on outcomes, and says it will rely on existing frameworks. Those are wide: the Consumer Duty, the Senior Managers and Certification Regime, and the rules on systems, controls and outsourcing all apply to whatever a firm does with an AI tool. No new rulebook does not mean no rules.
- FCA position
- No extra regulations planned for AI
- Relies on
- The Consumer Duty and senior manager accountability
- Treasury Committee
- Recommended practical guidance by the end of 2026
- Mills Review
- Published 6 July 2026, seven recommendations
The Consumer Duty, put to an AI tool
The Duty requires a firm to act to deliver good outcomes for retail customers. Each of its four outcomes can be asked of a tool.
- Products and services: is it fit for the customers it is used with?
- Price and value: does anyone pay more without justification?
- Consumer understanding: can customers follow it, and do they know it is automated?
- Consumer support: can a customer reach a person when they need one?
Accountability does not move to a supplier
Under the Senior Managers and Certification Regime a named senior manager is responsible for each area of a firm's business and must take reasonable steps to prevent breaches in it. Buying a tool does not change that, and outsourcing a function does not outsource the responsibility for it.
What is coming
In January 2026 the Treasury Committee recommended that the FCA give comprehensive and practical guidance on applying its consumer protection and accountability rules to AI by the end of 2026. On 6 July 2026 the FCA published the Mills Review of AI in retail financial services. Its first recommendation is to review general purpose AI tools that sit outside the regulatory perimeter but give outputs that look like financial advice. These are recommendations, not rules.
This page explains what the rule says. It is not legal, regulatory, clinical or financial advice on your own position. Rules change, so read the sources listed beside it, and tell us at hello@wajd.co.uk if something here is out of date.
Learn it properly, free
This guide is the summary. The course teaches it in full, with a video conversation, worked scenarios and a knowledge check after each module. Every module is free to read with no account. A certificate, if you want one once you pass, is £9.
AI at work, by industry · 1.5 CPD hours
AI in financial services: the Consumer Duty, accountability and the FCA's approach
- No new rulebook does not mean no rules 45 minutes
- Before a tool touches a customer 45 minutes
Questions people ask
Has the FCA published AI rules?
No. It has said it does not plan to introduce extra regulations for AI and will rely on existing frameworks.
Who is accountable when an AI tool harms a customer?
The firm, and the senior manager responsible for that area. Accountability does not transfer to the supplier.
Can a model decide a loan application on its own?
Since 5 February 2026 a solely automated decision with a significant effect is permitted on ordinary personal data with safeguards: the customer must be told and be able to make representations, obtain human intervention and contest it. The Consumer Duty and the Equality Act apply to the outcome.
Is the Mills Review binding?
No. It makes recommendations. The Consumer Duty and the accountability regime are the law now.