Articles

The Mills Review explained: what the FCA’s AI review means for financial services firms

July 7, 2026
5 min read

The FCA published the Mills Review on 6 July 2026. The 147-page report, led by executive director Sheldon Mills, examines how AI could reshape retail financial services by 2030 and makes seven recommendations to the FCA Board. This guide answers the questions compliance leaders, advice firms and boards are asking about it.

What is the Mills Review?

The Mills Review is the FCA’s report into the long-term impact of artificial intelligence on retail financial services. The FCA Board commissioned it and executive director Sheldon Mills led it. The FCA describes it as the first work of its kind initiated by a regulator anywhere in the world.

The review ran a call for input from 27 January to 24 February 2026, drew on 140 written submissions, and asked 20 questions across four themes: how AI will evolve, how it will affect markets and firms, how it will affect consumers, and how regulators need to change. The final report runs to 147 pages and was published on 6 July 2026.

Why did the FCA launch the review?

The FCA launched the review because AI is moving from a back-office efficiency tool to a more autonomous layer in how regulated financial services are delivered. The review expects that firms and consumers will delegate more financial decision-making to AI systems, which will recommend actions, initiate transactions and execute decisions within agreed parameters by 2030.

The pace of the technology shaped the report. More than 20 frontier models were released between the review starting in late 2025 and publication, alongside hundreds of smaller variants. The report treats that pace as the central driver of everything else in it.

Does the Mills Review introduce new AI rules?

No. The review concludes that the existing regulatory framework remains fit for purpose and recommends no new AI-specific rules. The Senior Managers Regime and the Consumer Duty stay in place unchanged, although the FCA is expected to clarify how both regimes apply where firms deploy autonomous AI.

Two follow-ups are already scheduled. The FCA will review the regulatory perimeter within three to six months, and a “good and poor practice” publication is expected later in 2026.

What are the four AI-driven changes the review identifies?

The review identifies four broad changes likely to reshape retail financial services:

The transformation of firms
The evolution of consumer journeys into agent-led ones
The reshaping of market power and competition
The amplification of threats and defences

The consumer point deserves attention from advice firms in particular. The review describes a future where AI agents continuously assess a consumer’s financial situation, suggest product switches and execute decisions automatically where the consumer has authorised it. Consumer research commissioned for the review, a Yonder survey of more than 5,000 UK retail financial services consumers in April 2026, found that around one fifth of UK adults may be likely to use AI that can act autonomously within pre-set goals.

What are the seven recommendations in the Mills Review?

The review makes seven recommendations for the FCA Board and Executive to consider:

Secure and adapt the regulatory perimeter
Strengthen system-wide coordination and oversight
Monitor the transition to autonomous models and adapt regulatory frameworks
Scale up the FCA’s AI Lab to support AI models and system innovation in financial services
Enable the foundations for agentic finance
Build and adopt an AI-enabled agentic supervisory model
Develop a trusted public-interest AI-enabled financial capability service

Decisions on which recommendations to take forward now rest with the FCA Board and Executive.

What is the Agentic Supervisory Model?

The Agentic Supervisory Model is the review’s proposal that the FCA build a set of AI-enabled tools to monitor outcomes across firms in near real time and detect risks that no single firm can see on its own. It signals that the regulator itself expects to use AI actively in supervision and risk detection. For firms, it points towards a supervisory relationship where the FCA reads outcomes data continuously rather than reviewing evidence after the fact.

What is the autonomy spectrum?

The autonomy spectrum is the review’s framework for explaining what changes as AI capability grows. It sets out five human roles, starting with the human as operator, using AI as a tool, then as collaborator, where the human and the AI plan and act together, and moving towards arrangements where AI systems act with growing independence inside agreed parameters. The report maps pressure points in the current regulatory framework against this spectrum, and finds that operational resilience and the regulatory perimeter come under pressure in the near term.

What does the Mills Review mean for the Consumer Duty?

The Consumer Duty stays in place and continues to apply. The review’s position is that firms need to apply their existing regulatory duties to increasingly autonomous systems. Where an AI system recommends actions or executes decisions for a customer, the firm remains accountable for the outcome under the Duty, and the FCA is expected to clarify how the Duty applies in the context of autonomous AI.

For compliance teams, the practical question is evidence. A firm that lets AI act inside its advice or service journeys needs records of what the system did, why, and what outcome the customer received, retrievable when the FCA asks.

What should firms do now?

The review sets no new obligations, so the actions for firms flow from applying existing rules to a more autonomous set of tools:

Map where AI already acts in your business. The review’s concern is autonomy, so the starting point is knowing which systems recommend, initiate or execute anything that touches customer outcomes.
Check your oversight evidence. Firms need to show how existing duties, including the Consumer Duty and the Senior Managers Regime, apply to each AI system in use, and produce records that demonstrate it.
Watch the two scheduled follow-ups. The perimeter review lands within three to six months of publication and the good and poor practice publication is due later in 2026. Both will show where the FCA’s expectations are settling.
Prepare for outcomes-level supervision. The Agentic Supervisory Model points to a regulator that monitors outcomes across firms continuously. Firms whose own monitoring covers all customer interactions will find that conversation easier than firms working from samples.

How Aveni fits in

Aveni builds AI for FCA-regulated financial services firms. Aveni Detect monitors customer interactions for compliance risk, and Aveni Assure supports assurance across advice processes, which gives firms the outcomes evidence the review’s direction of travel asks for. [Internal links: Detect product page, Assure product page, Mills Review webinar landing page.]