The FCA’s latest fair-value commentary stresses that firms need evidence showing the relationship between price, benefits and actual customer outcomes. It expects firms to assess different customer groups rather than treating the target market as homogeneous, and to test whether customers understand the total cost and commitments involved.
For advisers deploying AI in lead triage, product research, communication or file reviews, this is a useful governance prompt. Firms should maintain human oversight, test whether AI-supported processes produce consistent outcomes for vulnerable customers, retain auditable records, and challenge biased or unsupported recommendations. Existing data such as complaints, arrears, client feedback and product usage can help demonstrate that technology is improving—not obscuring—customer outcomes.