A watershed moment for financial services: What the FCA’s AI review could mean for payment firms

by Greenberg Traurig (Manish Das, Shareholder; Matt Hancock, Shareholder; and Maisie Stewart, Practice Group Lawyer)

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The FCA’s Mills Review explores how AI and agentic finance could reshape UK retail financial services, regulation and supervision by 2030.

The Financial Conduct Authority (FCA)’s “Mills Review” (the Review) explores the impact of artificial intelligence on UK retail financial services and builds on the FCA’s ongoing research in this area. Notably, it also offers proposals as to the potential evolution of regulation, based on the views of FCA executive director Sheldon Mills.

Published in July 2026, the Review authoritatively draws on engagement across the financial services industry, academia, consumer groups and other UK and international regulators. Based on this work, it finds a fundamental shift occurring in how retail financial services are delivered, used and supervised.

The four overarching themes

The Review identifies four systemic shifts which it predicts will reshape retail financial services by 2030: (i) the transformation of firms through AI-enabled automation; (ii) the emergence of agent-led consumer journeys, with an increase in delegation to AI applications; (iii) a reshaped competitive landscape driven by AI; and (iv) an increase both in threats and the capabilities to defend against them.

Cutting across all four is the “autonomy spectrum”. This is a sliding scale to help describe how human roles may evolve from operator to observer as AI systems take on greater decision-making authority. The Review suggests that, to begin with, humans will have full control. However, it notes that as retail financial services move further along the spectrum, the challenge for consumers, regulated businesses and regulation will grow. The Review notes that this is because, in the future, a human will not be involved in making every decision. Instead, it posits that human involvement will focus on instructing AI and overseeing outcomes. For payments firms, this corresponds to future transaction journeys (e.g. initiation, authentication and execution).

The Review concludes that the existing regulatory framework is sound but will need to evolve and notes that supervision by the FCA must also change. The Review states that it won’t be enough for the FCA to focus primarily on individual firms or trigger events, such as self-reporting of breaches. Instead, the Review notes that supervision will need to take a macro-view, looking at the whole ecosystem, and, to achieve this, the FCA will need its own AI-enabled supervisory capability. Developing this capability is one of the Review’s seven recommendations, alongside enabling the foundations for agentic finance.

Payments and agentic finance

AI agents are already in use by consumers to initiate or complete payments, raising issues involving trust, control, access and liability. However, the Review takes a broader look at agentic finance as a concept in which AI agents help consumers manage their finances (e.g. by monitoring savings, managing investment portfolios or switching providers). The Review recognises the potential for agentic finance to realise huge benefits, but it notes that, to do this, the FCA will have to grapple with the possible need to “authorise” AI and the corresponding and necessary liability model. Developing these elements may be key to the future success of agentic finance.

What this signals for the sector

The Review sees agentic finance as both a growth opportunity and a systemic risk that the FCA needs to tackle by evolving its regulatory infrastructure. For payments firms, this could mean regulatory changes and some uncertainty, but it also brings opportunities to influence the new regulatory landscape (e.g. what technical and legal standards are adopted). Shortly after the Review was published, the government opened its consultation on Modernising Payment Services Regulation. The government wants the UK to lead the way on agentic payments, and it recognises that this will require upgrading payments infrastructure and modernising payment regulations. This is an important opportunity because what emerges may power “Open Finance” in the future.

Alongside the FCA, the Competition and Markets Authority (CMA) has also been active in relation to agentic AI. It recently published a discussion paper examining the competitive implications of agentic AI. This marks an escalation in the CMA’s scrutiny of AI-driven market conduct. It also highlights the genuine debate at play between regulators over how to harness the benefits of agentic AI through better regulation. Timely and proactive engagement may pay dividends for firms prepared to take this step.

What is at stake is potentially a profound change to the UK’s retail financial services industry. According to the Review, those who control the AI layer “may influence which products are visible… where value is captured, shifting the customer relationship away from financial services providers”. Whilst this could create risks, it also presents an opportunity for consumers and businesses if the regulatory framework can foster an environment to realise these opportunities.

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Article by Greenberg Traurig

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