In this section

FCA SYSC

Senior Management Arrangements, Systems and Controls — SYSC 4 and SYSC 8 require operational resilience evidence for material outsourced services and critical functions, including AI-driven services.

ICO Article 22 (UK GDPR)

Where an automated decision has legal or similarly significant effect on a data subject, you must provide meaningful information about the logic involved — and Article 12 of the UK GDPR requires you to demonstrate compliance.

FCA Consumer Duty

Firms must evidence fair outcomes for retail customers. Where AI is in the decisioning loop, the firm must be able to show how a specific decision was made and on what data.

Why UK firms can't just wait for the EU deadline.

The EU AI Act creates the loudest extraterritorial pressure on UK firms, but the domestic obligations apply already. An ICO subject access request can land tomorrow. The FCA can ask about your AI agent governance at any supervisory review. Consumer Duty applies whether the AI is in scope of the AI Act or not.

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