The FCA says firms’ understanding of Consumer Duty expectations is improving, with 88% reporting that they understand what is expected when supporting consumers and embedding the Duty. At the same time, the regulator continues to stress consumer protection, clearer outcomes and reduced unnecessary reporting burdens.
Mortgage firms adopting AI should interpret this as a prompt to strengthen governance rather than simply accelerate automation. Whether AI is used for lead prioritisation, document processing, call summaries or client communications, firms need evidence that it supports good outcomes, does not unfairly disadvantage customer groups and can be challenged by staff. This is especially important for later-life, vulnerable and complex-borrower cases, where individual circumstances may not fit standardised data patterns.
A practical starting point is a documented AI register covering purpose, data inputs, known limitations, testing, human accountability and customer-impact monitoring. Efficiency gains are valuable, but advisers should be able to explain how technology supports—rather than substitutes for—fair, personalised advice.