Innovate Finance has submitted its formal response to the Mills Review, which examines the long-term implications of Artificial Intelligence (AI) for the UK's retail financial services sector. Our submission outlines a strategic vision for the UK to become a global leader in AI adoption by 2030.

Our submission emphasises that while the UK is well-positioned, realising the full potential of AI requires a bold, pro-innovation regulatory environment and the development of the "UK Tech Stack" and the co-dependencies of AI, Smart Data, Digital ID, and Blockchain. The success of AI is dependent on high-quality data and we urge the FCA to accelerate the roadmap for Open Finance to help power this technology.

We strongly advocate for maintaining an outcomes-focused approach rather than moving toward prescriptive rules, which could stifle innovation. There is also a need for the FCA to provide clearer expectations on assurance requirements for third-party AI , examples of what they consider to be good/bad practice, and to define model ownership under the Senior Managers and Certification Regime (SM&CR) to give leaders the confidence to deploy these tools.

In the response, we recommend a review of existing rules to remove "tick-box" barriers, particularly in areas like debt advice, affordability in lending, and financial promotions.

Competition regulators must also ensure that the market remains competitive, avoiding "gatekeepers" that might restrict access to data or models, particularly within the growing field of agentic payments. We also propose advancing KYA protocols, ensuring AI agents are verified and acting securely on behalf of legitimate users.

Innovate Finance remains committed to working with the government and regulators to ensure the UK remains at the forefront of the AI revolution in financial services and in the coming months, members will have further opportunities to meet with regulators to discuss how they can work together to achieve this.

Read the response here