FCA Mills Review: what it means for wealth managers and IFAs

In July 2026 the Financial Conduct Authority published the Mills Review, its landmark study into how artificial intelligence could reshape retail financial services by 2030 and beyond. Led by FCA executive director Sheldon Mills and commissioned by the FCA Board, it is not a new rulebook. It is a strategic roadmap — but one that tells wealth managers and IFAs a great deal about the regulator’s direction of travel, and about what it already expects of firms using AI today.

What the Review actually says

Drawing on industry engagement and a survey of more than 5,000 consumers, the Review describes a sector moving from human-led services towards ones that are increasingly AI-enabled, continuous and, in time, delegated to more autonomous “agentic” systems. It identifies four broad shifts: how firms operate, how consumer journeys work, how markets compete, and how fraud and cyber risks are amplified. It then makes seven priority recommendations to the FCA, including securing the regulatory perimeter and laying the foundations for “agentic finance.”

For advice firms, the most important point is what the Review does not do. It does not propose AI-specific regulation or a wholesale rewrite of the rules. Instead it concludes that the existing framework — the Consumer Duty, the Senior Managers and Certification Regime (SM&CR) and operational resilience requirements — is a strong enough foundation to govern AI, with clarification to follow on how those regimes apply as tools become more autonomous.

What it means for wealth managers and IFAs

The practical message is that accountability does not move to the machine. A recurring theme of the Review is that complexity is not a defence: firms must be able to explain and stand behind what their AI produces. For an IFA, that means a suitability report drafted with AI is still the firm’s report, and a named senior manager remains responsible for it under SM&CR. Keeping a human in the loop is not a nice-to-have — it is how the risk is managed.

The Consumer Duty angle is just as direct. As client journeys become more automated, firms still have to show that communications are clear and outcomes are good, and AI-generated client documents sit squarely within that scope. Because the Review also places heavy weight on data, cyber and operational resilience, any AI supplier an advice firm relies on should be able to answer hard questions about where client data goes and whether it is used to train external models.

There is opportunity in the Review too. It explicitly hopes AI can reduce friction and help close the advice gap — the very outcome advice firms achieve when they are able to serve more clients without lowering their standards.

Where this leaves advice firms in practice

For most wealth managers and IFAs, the sensible — and lowest-risk — place to use AI today is exactly where the Review’s logic points: assistive, back-office tasks kept under full human control, with report writing the obvious example.

This is the model Ammonite built Planbot around. The adviser or paraplanner stays firmly in charge, which aligns with the Review’s emphasis on human oversight and accountability. The firm controls the wording, sections and tone of every template, supporting the clarity the Consumer Duty demands. And on data, Planbot stores no client information, never uses it to train AI models, runs on UK-based Google Cloud.

It reflects a principle Ammonite’s founders — former advisers and paraplanners themselves — have argued from the outset: AI should take on the heavy lifting of drafting and formatting while professionals apply the judgement and keep responsibility for the advice. That is precisely the balance the Mills Review expects firms to strike as AI use grows. Faster, well-controlled report writing also frees capacity to serve more clients — the same advice-gap opportunity the FCA is keen to unlock.

You can see how that works in practice on the Planbot page, or follow the wider conversation in Ammonite’s Insights.

Frequently asked questions

What is the FCA Mills Review? 

It is a strategic review led by FCA executive director Sheldon Mills, published in July 2026, examining how AI could transform retail financial services by 2030 and beyond. It sets out seven recommendations to the FCA rather than introducing new rules.

Does the Mills Review introduce new AI rules for IFAs? 

No. It does not propose AI-specific regulation. It confirms that existing regimes — the Consumer Duty, SM&CR and operational resilience requirements — already apply to AI, with further clarification expected as the technology develops.

Who is responsible if an AI tool makes a mistake in a suitability report? 

The firm. A central theme of the Review is that complexity is not a defence, and a senior manager remains accountable under SM&CR. That is why meaningful human oversight of any AI-drafted document matters.

How does the Review relate to Consumer Duty? 

Consumer Duty still governs AI-generated client communications. Firms must be able to show that documents are clear and support good outcomes, however they were produced.

What should advice firms do now? 

Focus AI on assistive, controllable tasks such as report writing, keep humans in the loop, and scrutinise suppliers on data security. As always, confirm your approach with your own compliance function.