FCA Mills Review marks important shift in FCA’s thinking on AI

Charlotte Byrne, AI Lead at global technology and management consultancy Capco, discusses what the FCA Mills Review, published yesterday, means for the financial services industry.


The Mills Review marks an important shift in the FCA’s thinking. While until now, much of the conversation has been about how firms can adopt AI safely, this report goes further, clearly recognising that that AI is becoming part of the financial system itself.

The finding that one in five consumers would be willing to use agentic AI for financial decisions is particularly significant, highlighting that consumers are clearly becoming more comfortable with AI. While this indicates the potential for AI to narrow the advice gap and make high quality financial support available to many more people, it’s important to distinguish between curiosity and trust.

Consumers will not judge AI on how ‘intelligent’ it is, they will judge it on whether it delivers high quality outcomes consistently. As AI takes on more responsibility, the controls around it need to become stronger, not weaker.

When it comes to regulation itself, it’s particularly encouraging that the FCA hasn’t proposed an entirely new AI rulebook that risks becoming outdated. Instead, it builds on existing principles such as Consumer Duty, accountability and governance, while recognising that expectations need to evolve as AI becomes more autonomous. That feels like a pragmatic approach, that strikes the right balance, giving firms the confidence to innovate without creating unnecessary regulation.

For firms, the priority now is operationalising these principles. Most organisations understand what good AI governance should look like, but the harder part is embedding it from design and development through to deployment, monitoring and assurance. As AI becomes more autonomous, oversight, accountability and controls need to be built in from the start, not treated as a final-stage compliance check.

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