Consumer Duty Sets the AI Evidence Test

The FCA’s latest fair-value findings emphasise that firms need evidence showing a meaningful relationship between price, benefits and customer outcomes. Stronger firms segmented customers by factors such as credit risk, usage, channel and vulnerability, rather than assuming one broad target market receives the same value.

This is directly relevant to advisers adopting AI for segmentation, communications or workflow automation. AI can surface patterns from complaints, arrears, feedback, product usage and case outcomes, but the firm must be able to explain what the evidence shows, how it informed decisions and what action follows if poor outcomes emerge.

  • Ask: Does the tool identify different outcomes for distinct client groups?
  • Test: Can clients understand total cost, commitments and key trade-offs?
  • Evidence: Maintain oversight, human challenge and an auditable record of decisions.

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