Can an FCA-regulated firm use an AI worker?

Yes, for the paperwork around advice, and never for the advice. The Financial Conduct Authority (FCA), which regulates financial services firms across the UK, says it does not plan to introduce extra regulations for AI and relies on the rules a firm already works under. Under those rules the firm stays fully responsible for work it gives to someone else, a senior manager is accountable for the area it works in, and a recommendation is the firm's own. So an AI worker can chase, collate and draft. It cannot advise, assess suitability or decide what a client is told about their own circumstances.

Where is the line between paperwork and advice?

An AI worker has one role and a specification the firm has approved. That specification draws the line in two places.

First, routine requests and reminders go out in wording the adviser has approved in advance: the fact-find reminder, the request for payslips, the request for renewal information, the review booking.

Second, anything about one client's circumstances waits for the adviser's approval each time. A draft section of a report, a reply to a client's question, a follow-up letter after a meeting: the worker prepares it, and it stays a draft until the adviser approves it.

The worker never gives advice, never assesses suitability and never answers a client's question about their money. A client who asks "should I?" gets an adviser.

What has the FCA said about AI?

The FCA sets out its position on its page "AI and the FCA: our approach", first published on 8 September 2025: "We do not plan to introduce extra regulations for AI." It gives two examples of the existing frameworks it relies on: the Consumer Duty, and the Senior Managers and Certification Regime, under which senior managers are accountable for their areas of the firm.

So there is no separate AI rulebook to satisfy. The questions a compliance officer asks about an AI worker start where they start for an administrator or an outsourced paraplanner: who is responsible, and who checks.

Which existing rules apply?

• Outsourcing. SYSC 8.1.6R says that a firm which outsources critical or important operational functions remains fully responsible for discharging all of its obligations under the regulatory system. Senior personnel cannot delegate their responsibility by outsourcing. Whether a given admin role is a critical or important function is the firm's own assessment, and how the chapter applies to each kind of firm is set out in SYSC 1 Annex 1. An appointed representative acts under its principal's responsibility, so what it may hand to an outside provider is for the principal.

• The Consumer Duty. Principle 12 requires a firm to act to deliver good outcomes for retail customers. Its rules on consumer understanding require communications that meet customers' information needs, are likely to be understood and equip them to make effective, timely and properly informed decisions (PRIN 2A.5.3R). A reminder sent in the firm's name is the firm's communication, whoever drafted it.

• Senior managers. Every holder of a senior management function has a Statement of Responsibilities, and under the duty of responsibility can be held accountable for a breach in their area if they did not take reasonable steps to prevent or stop it. The work an AI worker does falls within the area a senior manager is responsible for.

• Advice and suitability. Advising a person on the merits of buying or selling a particular investment is a specified activity under article 53 of the Regulated Activities Order. A recommendation must be suitable for the client under the FCA's suitability rules, COBS 9 or COBS 9A depending on the business, and mortgage advice has its own (MCOB 4.7A.2R). An insurance broker must specify the customer's demands and needs before a contract is concluded and propose only a contract consistent with them (ICOBS 5.2.2R and 5.2.2BR).

How your firm meets those duties is for your compliance function and its own policies; nothing here is advice on compliance.

What can an AI worker take on?

In a financial advice firm: sending the fact-find and chasing its return, writing to providers with letters of authority and chasing the replies, and typing the factual sections of a report for the paraplanner (fact-find and suitability paperwork). For a mortgage broker: chasing the case documents a lender needs, checking that what arrives is the right document and in date (chasing clients for documents). For an insurance broker: starting each renewal ahead of its date, collecting the changes a client reports and preparing the file for the account handler.

What stays with a named person?

• The recommendation and its suitability. The adviser's, always.

• The demands and needs judgement in an insurance sale, and which contract is proposed.

• Approval of anything written about one client's circumstances, each time, before it is sent.

• A client who may be vulnerable, and every complaint. The worker passes them to a person and does not reply.

• Money. The worker moves none, takes no payment and has no access to client money.

• The approved wording itself. A change to a template is a person's decision, recorded.

What about client data?

The firm is the controller of its clients' personal data, and UK GDPR requires a written contract with whoever processes it on the firm's behalf; the terms are in AI workers and client data under UK GDPR. Where it is held and what it is used for takes one sentence: Your data is stored in the UK, and is never used to train AI models.

In an advice firm or a brokerage the worker would chase and collate in wording your advisers approved in advance, and the recommendation, its suitability and anything about one client's circumstances would stay with your advisers. Talk to our AI agent about the specification your compliance officer would want to read.