The FCA's October warning cuts straight to a genuine consumer protection gap: people are increasingly asking ChatGPT and Gemini for financial advice, and those platforms have no skin in the game, no duty of care, and no regulatory oversight. That is a real problem for vulnerable consumers. But here is what matters more to you: the regulator's second point, buried but critical. Firms are retrofitting governance after technology has been deployed. That is not a minor implementation oversight. Under FCA Consumer Duty PS22/9, you have a duty to act in the interests of consumers throughout the design, marketing and delivery of financial products and services. Retrofit governance is a confession that you did not. It is a compliance failure waiting for the enforcement notice.

This story sits alongside a broader shift in how regulated firms approach AI. The industry has spent three years watching external AI products (ChatGPT, Claude, Gemini) grab headlines and market share, then rushing to integrate them without asking whether they can do so safely. Meanwhile, purpose-built AI solutions designed specifically for regulated work—tools that embed governance, audit trails, role-based access, and output validation from the start—have been overlooked or deprioritised. The pattern is clear: firms are choosing speed over safety, and hoping regulators stay distracted by consumer-facing tools instead of looking at the compliance infrastructure inside their own systems. The FCA is now looking. That window is closing.

Trovix's view is straightforward: AI governance must be designed in, not retrofitted on. If you are implementing AI for client advice, matter intake, regulatory monitoring, or document work, the governance architecture has to exist before the system goes live. That means defined roles and permissions, traceable decision-making, output quality validation, and a clear audit trail from input to recommendation to client communication. Tools like Harvey and Legora have built strong foundations here for legal work. In financial services, the bar is higher because your liability is higher. You cannot use a generic chatbot as your compliance engine and call it risk management. You need systems that know your firm's regulatory obligations (Consumer Duty, COBS rules, ICOBS frameworks) and embed them into how the AI operates. Trovix Audit exists precisely because retrofit governance fails. It lets you build compliance into the system before deployment, not after.

Here is what you should do this week. First: audit what AI is running in your firm right now—intake systems, advisory tools, document analysis, regulatory research. Second: map each system against your specific regulatory obligations. Are the governance controls built in, or bolted on? If bolted on, you have work to do. Third: for any new AI implementation, make governance design a non-negotiable part of the requirements, not an afterthought. Trovix Watch can help you stay ahead of regulatory change as the FCA tightens its stance. The firms that will stay ahead of enforcement action are not the ones that move fastest. They are the ones that got governance right before they went live.

Source: City AM