Sep 28, 2026 · 14 min · 9 segments
By 2030, many firms could be operating AI across several functions at an approver level or beyond, according to the Financial Conduct Authority’s (FCA) Mills Review. Host…
Sebastian BarlingHost
Deborah KirkGuest
And look, my initial thoughts on the Mills review, it is deliberately, in my mind, correctly forward-looking.
So the review really asks, what is the financial system going to look like? And what will it demand of firms and the regulator in the future? And what will the stakeholders need to do in order to protect consumers?
And to bring some focus on how we're going to address it in this episode, We're going to be looking at a few key questions that we think will be of most importance to banks and financial institutions.
And in particular, we're going to cover what the autonomy spectrum means for oversight, what autonomy spectrum actually means.
We're going to talk about whether the senior manager regime and consumer duty will come under strain as this rolls out, what banks and financial institutions should be thinking about right now, as well as how the FSA plan to supervise an AI-enabled market.
And it is worth saying that institutions shouldn't look at this purely through a regulatory lens, right? The review, rightly in my view, treats AI as a truly systemic shift in terms of how it changes firm architecture, consumer behavior, market structure and fraud risk all at once.
It is also a flag of how the financial world is likely to change and how stakeholders need to prepare for that.
I mean, existentially might be too strong a word, but culturally and holistically certainly aren't.
I completely agree that this is a substantial development and material development for all financial institutions.
And it's going to be something that they will need to look at as they move up the autonomy spectrum.
And that is a term that most of you keeps coming back to as in the risks are going to evolve as autonomy increases.
Debs, would you like to unpack a little bit as to what we mean by autonomy spectrum so everybody's clear?
And look, my initial thoughts on the Mills review, it is deliberately, in my mind, correctly forward-looking.
So the review really asks, what is the financial system going to look like? And what will it demand of firms and the regulator in the future? And what will the stakeholders need to do in order to protect consumers?
And to bring some focus on how we're going to address it in this episode, We're going to be looking at a few key questions that we think will be of most importance to banks and financial institutions.
And in particular, we're going to cover what the autonomy spectrum means for oversight, what autonomy spectrum actually means.
We're going to talk about whether the senior manager regime and consumer duty will come under strain as this rolls out, what banks and financial institutions should be thinking about right now, as well as how the FSA plan to supervise an AI-enabled market.
And it is worth saying that institutions shouldn't look at this purely through a regulatory lens, right? The review, rightly in my view, treats AI as a truly systemic shift in terms of how it changes firm architecture, consumer behavior, market structure and fraud risk all at once.
It is also a flag of how the financial world is likely to change and how stakeholders need to prepare for that.
I mean, existentially might be too strong a word, but culturally and holistically certainly aren't.
I completely agree that this is a substantial development and material development for all financial institutions.
And it's going to be something that they will need to look at as they move up the autonomy spectrum.
And that is a term that most of you keeps coming back to as in the risks are going to evolve as autonomy increases.
Debs, would you like to unpack a little bit as to what we mean by autonomy spectrum so everybody's clear?
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