One in five UK adults is already open to letting AI make financial decisions for them. A quarter are taking mortgage advice from ChatGPT with no idea they have zero recourse if it goes wrong
The Mills Review, published by the FCA this month, is a carefully balanced document. It acknowledges risks, recommends safeguards, and is written in the measured language of a senior regulator who spent months consulting with industry. The FCA has thought hard about the future of AI in retail financial services.
Mortgage brokers should read it differently.
The review's central finding is that the shift in financial services is from human-led, episodic activity towards services that are AI-enabled, continuous and delegated. That shift is already under way. A joint survey by the Bank of England and the FCA, published in November 2024, found that 75% of UK financial services firms are already using AI, up from 58% in 2022. The Mills Review's own consumer research found that one in five UK adults is already open to AI making decisions for them outright - with demand strongest in debt advice, pensions and investments. The mortgage market sits directly in that frame.
The figure that lands hardest comes on page five of the executive summary: around 26% of UK adults trust general-purpose tools such as ChatGPT, Claude or Gemini for financial advice, despite limited awareness that formal routes to recourse will not apply.
One in four of your clients may be taking mortgage guidance from an unregulated AI. When it goes wrong - and it does go wrong - there is no ombudsman, no indemnity insurance, no FCA complaint process. There is nothing.
The accountability gap
Denni Tyson, founder of DT Financial, has already seen this play out. "The level of misinformation that is out there is quite frightening now for people," she told Mortgage Introducer. "The concern is the fact that people maybe start relying on it and it makes a mistake, which it openly says it can do, and there's just no accountability. You can't blame a computer."
The Mills Review confirms the structural reason why. It identifies a regulatory perimeter problem: general-purpose AI tools can shape financial decisions and influence competition without clear FCA oversight, because whether their activity falls inside or outside the regulatory boundary is currently unresolved. The review recommends securing and adapting that perimeter as its first priority. Recommendations take time. Your clients are using ChatGPT for mortgage research right now.
Rhys Edwards, mortgage consultant at Brooks Financial, draws the line plainly: "You can't fully rely on it just because AI says that a lender might do something or a rate might be available online." The Mills Review's data suggests a significant proportion of consumers have not reached the same conclusion.
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.
