Quick Comments From Payments Association on FCA’s AI Regulation Ambitions

“The FCA’s plan to use AI more extensively in its own supervision will enhance its supervisory capabilities. As regulators become able to analyse information and identify risks at greater speed and scale, firms will need to make sure the governance behind their own use of AI is equally robust.” 

“The FCA is right to focus on accountability, human oversight and operational resilience. Governance cannot be something firms retrofit once an AI system is already live. As AI becomes more autonomous, businesses need clear ownership, appropriate controls and plans for what happens when systems fail.” 

“This is particularly important for payments because the move towards agentic finance means AI will increasingly be able not just to provide information, but to act on a customer’s behalf, including managing and executing payments. It must be clear who is liable when an AI agent initiates a payment. Existing UK frameworks assume a person authorises each purchase, so the industry needs a shared way to evidence customer intent to clarify responsibility and give merchants certainty. Questions around identity, delegated authority and accountability therefore need to be resolved alongside innovation, rather than after it.” 

“With the FCA and Bank of England’s latest survey showing that 86% of financial services firms now use AI, this is no longer an emerging issue. The FCA’s pragmatic approach is welcome, but industry and regulators now need to move quickly together to give businesses and consumers clarity over where responsibility sits as AI becomes a more active participant in financial services.”