The Intermediary – August 2026 - Flipbook - Page 91
T E C H N O L O GY
Opinion
Governance is
a competitive
advantage
F
or much of the past three
years, discussions around
artificial intelligence (AI)
in financial services have
centred on technology.
Models have become
larger, processing has become faster,
and new solutions have emerged
almost weekly.
Somewhere amid the excitement,
however, an important question
for every business is sometimes
overlooked. Just because we can
automate something, should we?
The publication of the Financial
Conduct Authority’s (FCA) Mills
Review feels like an important
moment. Rather than asking whether
AI will transform financial services,
the Review focuses on something
more fundamental; how can firms
govern increasingly autonomous
technologies while continuing to
deliver good consumer outcomes?
AI is no longer confined to chatbots
or internal productivity tools. It is
beginning to influence underwriting,
fraud detection, customer servicing,
financial guidance and operational
decision-making. By 2030, AI could
fundamentally reshape how firms
operate, how consumers interact with
financial institutions, and even how
markets themselves function.
Perhaps understandably in an area
that is as fast moving as this, the
Review does not propose an entirely
new AI rulebook. Instead, Mills
reaches a more nuanced conclusion
where existing principles such as
Consumer Duty, the Senior Managers
and Certification Regime and
operational resilience remain broadly
fit for purpose.
The challenge is not, therefore, any
absence of regulation, but applying
those existing responsibilities to a
world where humans increasingly
supervise AI rather than perform
every task themselves.
This is an important nuance. For
time immemorial, firms have viewed
AI primarily through the lens of
efficiency. How much faster and
cheaply can we process applications?
How many customer enquiries can we
automate? How much manual work
can we eliminate?
Now, it seems, the businesses
likely to lead the next phase will not
necessarily be those deploying the
most sophisticated models. They will
be those able to demonstrate that
every automated decision sits within
a clear framework of governance,
accountability and human oversight.
Judgment and wisdom are becoming
more valuable than automation.
Traditional origination has required
experienced underwriters to spend
a remarkable amount of time
reconciling information rather than
assessing risk. Payslips are compared
against bank statements. SA302s are
checked against declared income.
Identity documents are validated.
Discrepancies are investigated. Much
of this work is essential, but relatively
lile constitutes true underwriting.
Today, technologies such as our
own Collect & Conclude demonstrate
how AI can extract information from
multiple document types, reconcile
it with trusted digital data sources
and present a consolidated, validated
view of the customer before the
underwriter even begins, preparing
the evidence upon which a judgement
is based. AI is not making the lending
decision, but it is making beer
decisions possible.
Evolving role
The Mills Review describes an
autonomy spectrum in which humans
gradually move from carrying out
JERRY MULLE
is UK managing director
at Ohpen
tasks themselves towards seing
boundaries, approving actions and
overseeing outcomes produced by AI.
This feels like an accurate description
of where many financial institutions
are already heading.
The role of the experienced
professional is evolving from
processor to supervisor, or from
administrator to decision-maker.
Governance is rapidly becoming
a source of competitive advantage.
Customers will not choose lenders
simply because they use AI. Nor
will regulators judge firms on how
advanced their models appear. They
will be judged on their outcomes.
Can the firm explain why a
recommendation was made,
provide evidence to support it,
demonstrate oversight, show good
human intervention? The beer AI
becomes, the more important those
questions become.
Financial services has always
depended upon trust. Trust that
decisions are fair. Trust that customers
are treated consistently. Trust that
institutions remain accountable
for the outcomes they produce. AI
amplifies these obligations.
The future of financial services will
not be defined by autonomous systems
operating independently of people. It
will be shaped by organisations that
understand where automation adds
value and where human judgement
remains indispensable.
The firms that thrive will bring
the two together through thoughtful
governance, robust oversight and a
recognition that wisdom remains the
one capability AI cannot automate.
Trust will never go out of fashion. ●
August 2026 | The Intermediary
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