The Mills Review: reshaping the FCA’s approach to AI in retail financial services

On 6 July 2026, the FCA published the final report of the Mills Review, setting out seven priority recommendations for how the FCA should respond as AI – and increasingly autonomous AI – reshapes retail financial services by 2030 and beyond. 

The Review does not propose AI-specific regulation or wholesale reform of the existing UK regulatory framework. Instead, it concludes that the current framework provides a strong foundation for AI-enabled finance, while recognising that a number of regimes, including operational resilience, the regulatory perimeter, the Senior Managers Regime and the Consumer Duty, will come under increasing pressure as AI systems become more capable and move further along the autonomy spectrum.

The Review’s central insight is that retail financial services are shifting from human-led, episodic activity to services that are AI-enabled, continuous and delegated. It defines an ‘AI autonomy spectrum’ to explain this transition, tracking the human role from ‘Operator’ and ‘Collaborator’ through to ‘Consultant, ‘Approver’ and, ultimately, ‘Observer’ where AI executes decisions and the human performs a monitoring role. As autonomy increases, so too does the complexity of accountability, oversight and redress.

In our separate briefing, we explore what this shift means in practice: how firm-level governance will need to evolve; the fraud and financial crime risks AI is expected to amplify; the pressure points it creates for redress, competition and systemic risk; and how existing regulatory frameworks are likely to be tested as firms progress along the ‘AI autonomy spectrum’. We also discuss the Review’s seven priority recommendations addressed to the FCA Board, and the concrete steps firms should be considering now, well ahead of any formal rule change.

The Mills Review does not itself alter the rules that apply to firms today. But it signals a clear direction of travel – and firms that treat it as an early indicator of the FCA’s evolving expectations will be better placed to respond as the FCA’s approach develops over the course of this year and beyond.

Read our full briefing here.