Has the FCA made new rules for AI in financial advice?

No. The FCA has said it will not introduce extra AI-specific regulations and will rely on existing frameworks instead: the Consumer Duty, the Senior Managers and Certification Regime, SYSC record-keeping, the financial promotion rules, and UK GDPR enforced by the ICO (FCA, AI and the FCA: our approach). An adviser running AI outside those rules is in breach of rules that already apply.

Can a UK adviser put client data into ChatGPT or another public AI tool?

No live client data should go into any public AI tool. Doing so is processing personal data under UK GDPR with no AI exemption, and a public tool can retain, log, or train on the input (ICO, Response to the consultation series on generative AI). Use anonymised inputs, or a contracted tool with a DPA, data residency, training-off, and a completed DPIA.

Who is accountable when an AI tool produces a bad client outcome?

A named senior individual, not the tool. The FCA applies the Senior Managers and Certification Regime to a firm's use of AI, so a senior manager remains responsible for the outcomes AI produces (FCA, AI and the FCA: our approach). "The AI wrote it" is not a defence, which is why every client-facing AI output needs a named human reviewer.

Do I need to keep records of AI-assisted client communications?

Yes. SYSC 9.1 requires orderly records sufficient for the FCA to monitor compliance (FCA Handbook, SYSC 9.1). If a complaint or review asks how a communication was produced and reviewed, having no record of the prompt, the output, and the sign-off is a record-keeping failure in itself, separate from the content.

What is the fastest way to make AI use compliant in a small advice firm?

Write down the governance: name a senior policy owner, keep an inventory of every AI tool in use, require a named human review before any AI output reaches a client, document the lawful basis and DPIA for any live-data workflow, and keep the record. The Consumer Duty and SM&CR already apply; the gap is usually that none of this is written down yet. --- Serra Education provides process and tooling consulting only, never Serra Wealth investment advice. This article is general information on AI-adoption process and governance. It is not investment, legal, or compliance advice. Each firm is responsible for its own regulatory compliance and for validating any AI output it relies on. Do not put live client data into any AI workflow that is not contracted and assessed for it. Regulatory references are to FCA and ICO sources current as at 24 July 2026; check the source for the position on the date you rely on it.

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