Blog/Financial services

    You can delegate the decision, not the accountability: AI and the SM&CR reasonable steps test thumbnail

    20 Jun 2026

    ·

    7 minute read

    You can delegate the decision, not the accountability: AI and the SM&CR reasonable steps test

    Under the Senior Managers and Certification Regime, accountability for what happens in a business area is personal and cannot be handed to a model. As AI takes on more decisions, the "reasonable steps" defence depends on evidence a senior manager can actually produce.

    The EU AI Act Article 12 logging requirement: what "automatic logging" actually demands of financial services AI thumbnail

    2 Jun 2026

    ·

    7 minute read

    The EU AI Act Article 12 logging requirement: what "automatic logging" actually demands of financial services AI

    High-risk AI obligations under the EU AI Act apply from August 2026. Article 12 mandates automatic logging, here is what that means in practice for financial services, and where most firms fall short.