Blog/Smcr

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

    20 Jun 2026

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    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.

    Consumer Duty and AI: evidencing good outcomes when the decision was made by a model thumbnail

    6 Jun 2026

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    7 minute read

    Consumer Duty and AI: evidencing good outcomes when the decision was made by a model

    The FCA will not write AI-specific rules in the near term. Instead, firms must demonstrate AI compliance through Consumer Duty, SM&CR, and SYSC 9, which raises a hard question about reconstructing model-made decisions.