The headline says “future-focused, technology-neutral”.
But one quiet line matters more than most people will notice:
“It builds on earlier AI Lab and AI Sprint work.”
That tells us something important.
The FCA has mainly explored AI inside institutions —
product development, operational tooling, regulated firm use-cases.
That’s understandable.
It’s what regulators can see.
It’s what firms bring to the table.
But it also leaves a gap.
The fastest shift in AI isn’t happening inside firms.
It’s happening with people.
Consumers are already using open AI tools to:
- understand complexity
- compare options
- model decisions
- challenge assumptions
- reduce dependence on intermediaries
This isn’t “AI as a product”.
It’s AI as a capability.
And that distinction matters.
If the conversation stays framed around institutional AI, we risk:
- reinforcing closed systems
- mistaking governance for protection
- solving the “advice gap” by scaling sales logic
If we widen the frame, there’s another possibility:
- AI as a tool for consumer agency
- planning before products
- clarity before commitment
- capability before compliance
That future doesn’t weaken Consumer Duty.
It may be the only way to fulfil it.
The FCA is asking for views.
This is one of those moments where how we frame the question shapes the outcome for a decade.
Question for reflection:
👉 Are we regulating AI as something firms sell — or something people use?
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Academy of Life Planning 