Which rules govern your use of AI

There is no separate FCA AI rulebook. Obligations follow the activity, the customer, the permissions and the use case, not the technology label, and not the sector on your website.

This map shows where to start looking. Every column links to its source so your compliance officer can check it rather than take our word for it.

Firm typeConsumer DutyPRIN 2AAdvice & recommendation standardsCOBS 9 / 9A · MCOB · ICOBSSM&CRSYSC 23–27Records, outsourcing & third partiesSYSC 8 / 9 · PSRs / EMRs where applicable
From 18 Mar 2027 PS26/2 splits: incident reporting is broad (all Part 4A firms + PSPs); material third-party reporting is narrow (enhanced SM&CR, banks, designated investment firms, CASS large, authorised payment/e-money)
Operational resilienceSYSC 15AUK GDPR & automated decision-makingArts. 5–35 · Arts. 22A–22D · DUAA 2025 · ICO ADM/AI guidance
Automated-decision provisions bite only where a significant decision is made without meaningful human involvement
Vulnerable customersFG21/1EU AI Act2024/1689 · Art. 2
amended by 2026/1744
Retail financial advice — IFAAdvising retail clients on investments
Wealth & discretionary managementPortfolio management, mixed client base
Mortgage intermediaryMCOB business
Protection & general insurance intermediaryICOBS business
VC — FCA-authorised managerProfessional / institutional investors only
PE — FCA-authorised managerProfessional / institutional investors only
Authorised payment or e-money institutionPI · EMI · RAISP
Unregulated fintech / AI vendorSelling software into regulated firms
Accountancy & professional servicesMay hold DPB or limited permissions
Typically directly applicable
Depends on permissions, activity, customer or use case
Typically outside direct scope
May become a regulated-buyer requirement — not a direct FCA obligation
Consumer DutyTriggered by activity within the relevant retail market and the firm's role in the distribution chain — not by a job title or firm type. It reaches firms that determine or materially influence retail outcomes even without a direct client relationship. For wholesale-only VC and PE business it is typically outside scope; check retail distribution-chain exposure before relying on that.
Advice & recommendation standardsOne column, several rulebooks. COBS 9A covers investment advice and portfolio management in the specified MiFID and IBIP circumstances; COBS 9 covers suitability outside those circumstances; mortgage advice sits in MCOB and general insurance in ICOBS. Read the one that matches your permissions rather than assuming COBS 9A.
SM&CRApplies across solo-regulated firms but not identically — Limited Scope, Core and Enhanced carry different requirements, and the enhanced threshold also determines whether SYSC 15A reaches you.
SM&CR and paymentsPayment and e-money institutions are not currently within SM&CR — the regime reaches solo-regulated firms authorised under FSMA, and the FCA has separately suggested extending it to payments and e-money, which confirms they sit outside it today. The same firm can be expressly inside SYSC 15A and outside SM&CR at once; that is what the framework produces, not an error in the table.
SM&CR is mid-reformPhase 1 changes took effect 24 April 2026, with staged follow-ons through September 2026 — 12-week rule, criminal record checks, SMF7 scope, Statements of Responsibilities and enhanced-firm thresholds. Phase 2 depends on Treasury legislation. Anything you write about SM&CR now needs a review date.
SM&CR and fund managersThe grey cell reflects the breadth of the row, not a view that fund managers escape SM&CR. A full-scope UK AIFM has explicit Handbook treatment; narrow the row to that and the cell would be blue.
Records & third-party controlsSYSC 8 and 9 are the source for many FCA firms, but not a universal one — sector rules in COBS, MCOB, ICOBS and, for payment and e-money institutions, the PSRs and EMRs also carry record-keeping obligations. Read this column as "there are record obligations here", not "SYSC 8/9 is the source".
Operational resilienceSYSC 15A.1.1 lists its own scope: enhanced-scope SMCR firms, banks, designated investment firms, building societies, Solvency II firms, UK RIEs, EMIs, payment institutions, registered AISPs and consolidated tape providers. A typical IFA or wealth manager is inside only if enhanced scope — which is why those rows are grey and the payments row is blue.
Vulnerable customersFG21/1 is guidance rather than rules, but the FCA expects firms to show how they have had regard to it. It applies where the Principles apply, to retail customers who are natural persons, and can bite without a direct client relationship.
Check itFG21/1 ↗
UK GDPR & automated decisionsApplies wherever personal data is processed; exemptions and qualifications exist within the UK GDPR and DPA framework. The law here changed in 2026. The Data (Use and Access) Act 2025 replaced Article 22 with Articles 22A–22D: significant solely automated decisions are now permitted more broadly for non-special-category data, subject to mandatory safeguards — information, the ability to make representations, human intervention and a right to contest. Automated significant decisions using special-category data remain more restricted. Meaningful human involvement must be real rather than token. AI uses likely to create high risks will often require a DPIA. Note the ICO's guidance on this is itself still in draft consultation.
EU AI ActReach is by role, use case and EU nexus — provider, deployer, importer or distributor — not by sector or head office. Article 2 can capture a third-country actor where the system's output is used in the Union, so a UK company with no EU subsidiary is not automatically outside it. Certain financial-services uses can fall into the high-risk regime: assess the use case, not the firm type.
Critical Third PartiesNot a column here, but it changes the third-party conversation. HM Treasury announced AWS EMEA, Google Cloud EMEA, Microsoft Ireland Operations and Oracle UK on 10 July 2026; the designations took effect and joint Bank of England, PRA and FCA oversight began on 13 July 2026. The regime places no additional explicit requirements on regulated firms — responsibility for your own third-party arrangements does not move. In practice, though, your regulator now has a direct line to your largest suppliers.
The provision that matters most for AI

The suitability rules address automation directly, and in terms:

"A firm that provides investment advice or portfolio management services (in whole or in part) through an automated or semi-automated system remains responsible for the suitability assessment required by this section. That obligation is not affected by the use of an electronic system in making the personal recommendation or decision to trade." COBS 9A.2.23 R — verified against handbook.fca.org.uk, 4 September 2026

Note what it does and does not say. It does not require a human to make every decision. It says the firm remains responsible. So the question is never "is the tool approved". It is "can the firm evidence how responsibility, oversight and suitability were maintained where automation was used". Every control we teach exists to answer that.

If you are the vendor, not the firm

Selling AI into a regulated firm? Most of the FCA columns above do not bind you, and that is not the relevant question. Your customer's obligations become your commercial requirements.

A bank, wealth manager or advice firm will ask for evidence on governance, record-keeping, data protection, resilience, human oversight and client outcomes before your software touches client data. You may not be directly subject to their FCA rulebook, although GDPR and possibly the EU AI Act reach you in your own right. But if your product prevents them satisfying theirs, procurement is unlikely to approve you.

What is changing

Cells in this table will move. Rather than repeat the timetable here, it lives on its own page: every dated change to 2028, what work each one creates, and who it actually binds.

The nearest change to this page: the ICO's guidance on Articles 22A–22D is still in draft consultation, so the data protection column is the first one likely to move.

Two routes from here

Your sector tells you which questions to ask. It does not answer them. Five things settle your actual position: permissions, client classification, activities, where AI touches the file, and geography.

If you are the regulated firm

What must we satisfy when we use AI?

The readiness check walks through those five and returns a written report naming each gap and what closes it.

If you sell into regulated firms

What must our product demonstrate before they buy?

The evidence a regulated buyer will ask for before your software touches client data — ready in advance, rather than assembled during a procurement cycle.

Sources

FCA Handbook

handbook.fca.org.uk

PRIN 2A, COBS, MCOB, ICOBS, SYSC. Every chapter states its own application.

COBS 9A.2 — suitability

handbook.fca.org.uk — COBS 9A.2

Including 9A.2.23 R on automated and semi-automated systems.

SYSC 15A.1 — application

handbook.fca.org.uk — SYSC 15A.1

The operational resilience scope list, in the Handbook's own words.

FG21/1 — vulnerable customers

fca.org.uk — finalised guidance

Applies where the Principles apply, to retail customers who are natural persons.

ICO — AI and data protection

ico.org.uk

DPIAs, Article 22, and the regulator's own AI guidance.

EU AI Act

eur-lex.europa.eu — Regulation 2024/1689

Check Article 2 for territorial scope, and the authentic OJ text rather than a consolidated version.

Verification

What has been checked, and what has not

This stays on the page in whatever state is true.

COBS 9A.2.23 — automated systems Verified

Read directly from the Handbook on 4 September 2026 and quoted verbatim above. It is a Rule, not guidance, last updated 23 October 2025. The corresponding provision for insurance-based investment products is COBS 9A.2.24 G.

SYSC 15A.1.1 — resilience scope Verified

Read directly from the Handbook on 4 September 2026:

Applies to a firm that is an enhanced scope SMCR firm, a bank, a designated investment firm, a building society or a Solvency II firm; a UK RIE; an electronic money institution, a payment institution or a registered account information service provider; and a consolidated tape provider. SYSC 15A.1.1 R — paraphrased from the Handbook list. A future version is dated 25 October 2027.

Automated decision-making — the law changed Verified at the ICO

An earlier draft of this page described "Article 22 restrictions". That is out of date. The Data (Use and Access) Act 2025 replaced Article 22 with Articles 22A–22D, and significant solely automated decisions on non-special-category data are now permitted more widely, subject to mandatory safeguards. Read at the ICO on 4 September 2026 — where the guidance itself is currently in draft consultation, so this column needs the earliest review date on the page.

SM&CR scope — payments and e-money Verified

The FCA describes SM&CR as reaching solo-regulated firms, and has separately proposed extending it to e-money and payments firms — which establishes that they are outside it now. Checked 4 September 2026. The pale cell in that row is therefore evidenced, not inferred.

Source links Checked

Every URL resolves to the official page it claims.

Coloured cells Applicability assessment

Indicators reflect MoiraCorp’s assessment of where each regime is likely to be relevant to the stated firm type. Actual application depends on permissions, activities, client classification, territorial scope and use case. The regimes, cited provisions and forward dates themselves have been checked against primary sources and are linked above.

Forward dates Verified at source

CP26/23 (FCA, 29 Jun 2026, closes 18 Sep 2026, final rules Q1 2027), PS26/2 (FCA, published 18 Mar 2026, applies 18 Mar 2027), the UK cryptoasset regime (FCA, final rules 30 Jun 2026, regime 25 Oct 2027) and Regulation (EU) 2026/1744 (adopted 8 Jul 2026, in force 27 Jul 2026) have each been read at source. High-risk AI application dates under amended Article 113: 2 Dec 2027 (Art. 6(2)/Annex III) and 2 Aug 2028 (Art. 6(1)/Annex I).

Corrections

If you believe a cell is wrong, tell us. We will change it and say that we did.

Last regulatory review: 4 September 2026 · Next review: on publication of the FCA's good and poor practice material on AI, or 1 December 2026, whichever is sooner.

Regulatory mapping for operational planning, not legal advice. Applicability depends on permissions, activities, customers and facts. Primary sources are linked throughout; firms should confirm their own position with their compliance or legal advisers.

MoiraCorp Academy — Technical Library

From the matrix to your policy

The matrix tells you which rules apply. Regulator-Ready AI turns that into your firm’s policy, the registers behind it and the accountability mapping — £1,495 for a firm licence covering five people, or we can do it with you and evidence it, priced on application.