AI Hallucinations Affecting Marketing & Communications at Retail Banking Firms in the United Kingdom

Findings — impact summary

This is the consolidated view of findings. Click 'see details →' on any item for the full details for each finding.

1. Finding 1. Consumer testing obligation under the Consumer DutyRLB-F-GB-FCA-CONSUMER-DUTY-PS22-9-Q007

   If a Marketing & Communications team uses the AI's answer to build or update its Consumer Duty communications framework, the firm may implement testing obligations framed as binding rules where none of that specific form exists, or — equally — may overlook the genuine outcome-based obligation that PRIN 2A.5 does impose. Either outcome creates an implementation gap that the FCA could identify during a supervisory review or thematic examination of Consumer Duty compliance.

   The FCA has publicly stated its intention to scrutinise firms' good consumer understanding outcomes; a firm that cannot demonstrate a coherent and rule-accurate approach to communications review faces potential requirement notices, remediation obligations across its retail communications estate, and reputational exposure if findings are disclosed. The cost of retrospectively auditing and correcting a communications framework applied across a large retail book — and retraining staff briefed on incorrect obligations — is a material operational burden that falls on the firm, not on the AI tool that generated the original error.

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