AI for Lenders: Legal Shifts, FCA Testing, and What to Do Next

Pete Gatenby

September 10, 2025

AI for Lenders: Legal Shifts, FCA Testing, and What to Do Next

Each month, Pete Gatenby, AI Practice Partner at Novus Strategy & Consulting Ltd, breaks down the latest AI shifts in home buying and lending – with real-life use cases, guidance on safe and compliant adoption, and a view of what’s coming next.

AI continues to reshape financial services faster than ever, but value doesn’t come from the technology in isolation. The real gains happen when AI connects across workflows, systems, and customer journeys. That’s why Horizontal Digital Integration (HDI) matters: it’s the enabling strategy that makes AI a tool lenders can actually scale, rather than a set of disconnected pilots.

This month’s bulletin covers four major shifts lenders need to know:

  • EU AI Act deadlines are now fixed – with explainability a non-negotiable requirement by August 2027. If your models can’t demonstrate it, you’ll need to upgrade.

  • The FCA’s AI Live Testing Window – applications close on 15th September, with cohort work starting 3rd October. It’s more than just a sandbox: it’s a way to set future-proof standards around consumer duty, rollback, and monitoring.

  • The UK AI Safety Institute’s Inspect Toolkit – now live, giving lenders a ready framework to test agents safely and capture the evidence regulators will expect.

  • Real workflow shifts – from safe agent triage to document AI at scale, to retention analytics tackling winter’s payment shock.

The big message? Build the HDI rail first, then run agentic AI use cases off it. Data flowing horizontally is what turns proofs of concept into production outcomes.

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