From AI innovation to consumer outcomes: The FCA’s next regulatory focus

The FCA has launched two significant initiatives that signal its evolving approach to financial services: the Mills Review on artificial intelligence (AI) and an exploratory review into how firms monitor consumer outcomes under the Consumer Duty.

Together, they highlight an increasing supervisory focus on how technology, governance and customer outcomes intersect.

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Matthew Drage

Director - Technology Solutions

Square 4

AI and the future of financial services

Led by FCA Executive Director Sheldon Mills, the Mills Review explores how advanced AI could reshape retail financial services through 2030 and beyond. AI is already widely used in areas such as fraud detection, credit decisioning, pricing optimisation and customer support. The FCA is now focusing on how more advanced and interconnected systems could affect market structure, competition and consumer trust.

The regulator has indicated it does not expect to introduce a new AI specific regulatory regime. Instead, it is assessing whether existing frameworks such as the Consumer Duty, SMCR and operational resilience requirements remain fit for purpose in an increasingly AI enabled environment. This reflects the FCA’s outcomes based approach, supporting innovation while ensuring markets function well and consumers receive good outcomes.

A parallel focus on outcomes monitoring

The FCA has also launched a targeted review into how firms monitor and remediate consumer outcomes in practice. The objective is to understand how firms assess outcomes, identify emerging risks and take action where standards fall short. Insights will inform future supervisory and policy work, with findings expected in a Good Practice and Areas for Improvement report in Q2 2026.

The review focuses on three areas: the strategies and frameworks firms use to monitor outcomes, the role of data and management information including the use of AI, and governance, oversight and board accountability. The process will include desk based reviews of 2025 Consumer Duty Board Reports, followed by targeted information requests and, in some cases, further engagement.

Strengthening assurance in an AI enabled environment

Both initiatives reinforce the importance of strong governance. Under SMCR, responsibility for outcomes cannot be delegated to algorithms, and senior managers must demonstrate effective oversight and challenge of AI driven processes.

As automation expands, traditional monitoring approaches may struggle to keep pace. Firms are increasingly turning to data driven, technology enabled methods to assess outcomes at scale and generate clear, auditable evidence.

This is driving interest in structured outcomes testing and managed assurance services. Solutions such as Assure 4, developed by Square 4 Partners, combine regulatory expertise with AI enabled analytics in a human in the loop model, helping firms continuously
monitor customer journeys and evidence how outcomes are being assessed and improved.

As regulatory scrutiny of AI and outcomes monitoring continues to evolve, firms that invest early in scalable assurance frameworks will also be better positioned to demonstrate compliance, strengthen governance and build long term customer trust. At Square 4, we are also seeing increasing demand for frameworks that connect technology governance, AI oversight and Consumer Duty monitoring.

Read our Assure 4 brochure and Outcomes Monitoring whitepaper to find practical insights into assessing customer outcomes, identifying risks early, and strengthening the link between monitoring and decision-making.

About Square 4

Square 4 was founded with the vision to support people and businesses to grow and thrive across the evolving spectrum of conduct, financial crime and operational risk. We do this by leveraging technology and expertise to design bespoke solutions across our core service lines of: governance, risk and compliance, fraud and financial crime, technology solutions and people.

We provide an unrivalled level of interaction – service and expertise, supporting firms across a diverse and changing regulated agenda.

We have extensive experience incorporating the ‘big four’ professional service firms, industry regulators, leadership roles within Global Systemically Important Financial Institutions and other outsourced learning, resourcing and consultancy providers. We combine this with best-in-class technology to support firms to manage regulatory risk, ensuring clients meet the diverse needs of their stakeholders and customers.

For more information, visit www.square4.com.

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