AI is here to stay and its impact is likely to grow more profound over the coming years. Many firms have already adopted key AI systems over the past ten years to assist with functions such as automated trading, underwriting, combatting fraud and producing credit decisions.
With this in mind, the FCA has launched the Mills Review, the aim of which is to assess the future impact of AI on consumers, financial markets and firms.
This is not an untrodden path. The FCA is seeking to build upon its existing work in relation to AI but with a renewed focus on its impact from 2030 and beyond. As part of the Mills Review, views are now being invited on four key interwoven themes:
- How AI systems may evolve in the future: this includes discussion on the rising prevalence of agentic systems and the trend towards increasing autonomy.
- The impact on financial markets and firms: many firms will already be well placed to discuss the extent to which they have adopted these systems, but the FCA will be looking at the impact on competition at a national and firm level and on market structure.
- How consumers will be affected: the rise of AI will undoubtedly bring changes to the way consumers interact with financial services and how markets are shaped. Some of the key risks identified by the FCA include "AI enabled fraud and identity abuse, algorithmic bias and opaque decision making".
- How regulators might need to evolve: there is no intention to introduce a separate regime to the Consumer Duty to address these risks. Instead, this review will help shape how the Consumer Duty is applied, interpreted and enforced.
The deadline for comments is 24 February 2026, with the results to be discussed at the FCA Board in the summer, hopefully producing greater clarity on the direction of travel.
It is clear from FCA discussions that it recognises the benefits that emerging technologies can bring and that, if regulated appropriately, they can complement existing expectations under the Consumer Duty to deliver good outcomes for consumers.
