The Consumer Duty obligations introduced in July 2023 place the responsibility for demonstrating good outcomes squarely on regulated firms. If a client comes to you having made a decision partly based on AI-generated misinformation, the question of who is responsible for unpicking it lands on the adviser. The AI tool is not accountable. You are.
The advice gap AI is supposed to close
The Mills Review sees the advice gap as being real, large and expensive. Only 9% of consumers currently use traditional financial advice. £300 billion sits in low-interest accounts. Around 900,000 adults in the UK are unbanked. These are genuine failures of the current system.
The review’s argument is that AI can close these gaps by combining a consumer’s own data with wider knowledge to provide insights and recommendations – and eventually, to execute decisions on their behalf. On mortgage switching specifically, the review identifies low switching as one of the longstanding problems AI is positioned to address.
Only 12% of buyers say they would fully trust a standalone AI mortgage platform, and 30% still actively prefer advice from a human adviser. But the Mills Review’s autonomy spectrum suggests those numbers will shift as AI systems become more capable and more embedded in everyday financial life. The consumer who today uses AI to compare products and then comes to a broker to decide will, by the review’s own projection, increasingly use AI to compare, recommend and execute – with human involvement dropping to a sign-off rather than a conversation.
As Babek Ismayil, founder of OneDome, put it: “AI will not replace mortgage brokers. But it will replace firms that fail to adapt – firms that continue to think about mortgages in isolation rather than the broader customer journey.” The threat is not AI replacing the broker overnight. It is AI gradually absorbing the parts of the broker’s role that feel routine – product comparison, affordability indicatives, rate alerts – while the broker’s remaining value shrinks to the complex cases and the difficult conversations.