Karsten Wenzlaff, Advisor
August 26th, 2025
Karsten Wenzlaff is a Crowdfunding and Fintech Expert from Germany. He is Secretary-General of Digit[...]
Mills Review Response Targets AI Execution Barriers
Mar 19, 2026 | NCFA Feature | AI Finance Policy
UK Industry Sets Clear AI Policy Priorities
On Jan 27 2026, the UK Financial Conduct Authority launched the Mills Review into the long term impact of AI on retail financial services to examine how AI could reshape consumers, firms, markets, and regulation through to 2030. NCFA flagged the review earlier in NCFA Weekly Fintech Intelligence Jan 24-30, 2026.
On Mar 4 2026, Innovate Finance submitted its response to the Mills Review, setting out where the UK fintech industry believes deployment will stall unless policy and infrastructure move faster. The paper cites Bank of England and FCA data showing 75% of firms now use AI, up from 58% in 2022. The issue is no longer whether AI adoption will happen. It is what still blocks firms from using AI inside live financial workflows at scale.
What The Industry Is Asking For
- Keep AI regulation principles based and outcomes focused. The point is to avoid rigid rules that will age badly as models and tools change.
- Give firms clearer examples of good and poor practice. High level principles are not enough when firms need to deploy AI in regulated settings.
- Clarify assurance requirements for third party AI tools and for senior managers responsible for them. Most firms will not build every model in house, so external model use needs a clearer control standard.
- Review the rulebook and remove blockers in high value AI use cases. The paper points to debt advice, affordability in lending, agentic payments, and wallets.
- Prevent gatekeepers from controlling access to models, data, or agents, especially in payments. If a small number of providers control that layer, they can control distribution.
- Move Open Finance, digital assets, and Digital ID forward at the same pace. AI in finance depends on trusted data, verified identity, and usable infrastructure.
- Back this with a strategy to make the UK the world leader in AI adoption in financial services by 2030.
Why These Asks Matter
AI is clearly evolving from chatbot assistance to execution at scale. The submission describes AI agentic systems that can act on behalf of users. One example is an AI bot that handles everything from comparing mortgage deals to submitting the application and coordinating with conveyancers under user permission.
The value is no longer only in the model itself (ie. speed, quality, cost, expertise), but rather the full operational chain from customer permission to data access to execution to payment. That's why industry is focused on a stacked layer of tech solutions from Open Finance and Digital ID to payment access and rulebook friction to ensure AI can fully complete financial tasks.
See: Pro Human AI Declaration Gains Backing Across Sectors
The same logic applies to industry concerns over gatekeepers. As AI agents begin to initiate and route transactions, control moves to the layer that connects the agent to the payment method and the financial product. If that layer becomes concentrated, a small number of providers can influence access, routing, and competition.
The response uses real commercial examples and market data, highlighting that AI in finance is already underwriting, trading, core banking, and compliance.
- One embedded finance platform says it's facilitated more than £7 billion in SME revenue worldwide and is twice as likely to approve financing for female-owned businesses compared with the UK average.
- A core banking technology provider says it was last valued at $2.7 billion and employs more than 500 people globally.
- The submission also notes that algorithmic trading accounts for roughly 60% to 75% of activity across major U.S., European, and Asian markets.
- It adds that the RegTech market could reach $88 billion by 2032.
The next phase isn't whether or not firms can build AI tools. It is whether regulation and infrastructure will allow them to use those tools in broader customer and transaction flows.
The stronger points made is that AI in finance won't scale on model quality alone. It will however scale on the stack around the model. That means smart data, Open Finance, Digital ID, fraud data sharing, wallet infrastructure, and payment access. Without those layers, AI stays stuck in narrow support roles. With them, it can move into lending, advice, payments, and automated execution.
See: India’s AI Declaration Pulls In BRICS And Western Powers
That is why the response is more useful than another generic values and ethics based AI policy statement. It identifies where deployment slows, where control could become concentrated, and what has to move together if the UK wants AI to scale significantly inside financial services.
Why This Matters For Canada
Canada is also building its next AI strategy. The federal government launched an AI Strategy Task Force in September 2025 as part of a 30 day national sprint, and later said it heard from more than 11,000 Canadians and 28 task force members. The Canadian process is broad. It is focused on national AI leadership, trust, safety, adoption, and public interest.
That broad approach is already raising execution questions. NCFA covered this earlier in its analysis of Canada’s AI strategy and capital flight risk, which argued that deployment, investment, and commercialization need clearer direction.
The UK industry response to the Mills Review is more targeted. It focuses on what is blocking AI deployment inside financial services today. Open Finance, Digital ID, payment access, wallets, third party model assurance, and rulebook friction sit at the center of that response.
See: Google Signs EU AI Code Despite Competition Warnings
Canada is still discussing the national direction of AI while UK fintech industry is already laying out what has to change for AI to work inside live financial workflows. The lesson for Canada is straightforward. AI policy cannot move on its own. Open Finance, Digital ID, wallet policy, payments modernization, and data access frameworks need to move with it or adoption in regulated finance will stay limited.
There is also a market structure lesson. If agent led payments grow, whoever controls the interface between the agent, the wallet, and the payment rail can control distribution. Policymakers who want competition and innovation to hold need to keep that layer open.
Takeaway
The industry response to the Mills Review is not just a call for clearer AI rules. It argues that the next barrier sits outside the model. Data access, identity, payments, and regulatory clarity now decide whether AI in finance stays at the support layer or moves into execution. The firms and jurisdictions that solve those bottlenecks will have the advantage.
The National Crowdfunding & Fintech Association (NCFA Canada) is a financial innovation ecosystem that provides education, market intelligence, industry stewardship, networking and funding opportunities and services to thousands of community members and works closely with industry, government, partners and affiliates to create a vibrant and innovative fintech and funding industry in Canada. Decentralized and distributed, NCFA is engaged with global stakeholders and helps incubate projects and investment in fintech, alternative finance, crowdfunding, peer-to-peer finance, payments, digital assets and tokens, artificial intelligence, blockchain, cryptocurrency, regtech, and insurtech sectors. Join Canada's Fintech & Funding Community today FREE! Or become a contributing member and get perks. For more information, please visit: www.ncfacanada.org
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