FCA’s AI Live Testing Engagement Paper

  1. Introduction

In April 2025, the Financial Conduct Authority (FCA) released an Engagement Paper outlining its proposal for AI Live Testing as part of its AI Lab initiative. This programme aims to support the safe and responsible adoption of Artificial Intelligence (AI) in UK financial services, fostering innovation, economic growth, and consumer protection.  

AI Live Testing will allow firms to deploy AI models in controlled live market environments, with access to regulatory support and synthetic datasets to ensure compliance and positive outcomes. The FCA invites feedback on this proposal by 10 June 2025, with the program set to launch in summer 2025. 

  1. Scope

AI Live Testing, integrated into the FCA’s AI Lab, focuses on addressing challenges firms face before deploying AI models in UK financial markets. The goals of the programme include: 

  • Develop a shared understanding of AI evaluation methods, model metrics, and benchmarks for safe AI use across its lifecycle. 
  • Provide access to AI and regulatory expertise 
  • Explore validation methods, robustness metrics, bias measurement, and consumer impact, particularly for vulnerable groups, without covering AI auditing or corporate governance. 
  • Support firms transitioning from Proof-of-Concept (PoC) to live market deployment, ensuring appropriate risk identification and safeguards are in place.  

The initiative complements existing FCA innovation services like the Regulatory Sandbox and Digital Sandbox, targeting AI models ready for live market interaction. 

  1. Considerations for Firms

Participation in AI Live Testing is voluntary and open to firms providing financial services or AI models that are material to UK financial markets. To be considered, firms must meet competitive selection criteria, including: 

  • Active use of AI in a significant financial services use case. 
  • A developed PoC with plans for live deployment. 
  • Demonstrated pre-deployment testing to ensure readiness for a controlled rollout. 
  • Clearly outlined post-deployment monitoring plans and a willingness to share findings with the FCA. 
  • Alignment of the AI use case with the FCA’s operational objectives (consumer protection, market integrity, and effective competition) and support for the UK’s economic growth. 
  1. Next Steps for interested Firms

Firms interested in AI Live Testing should: 

  • Review the Engagement Paper and provide feedback by 10 June 2025 
  • Prepare for the application process, opening in early summer 2025, ensuring their AI use case meets the selection criteria. 
  • Engage with the FCA to discuss potential use cases, such as loan and credit provisioning, and prepare documentation demonstrating readiness for live testing. 

The FCA intends to publish interim findings and a final report over the next 12 months. Success will be evaluated through metrics such as the number and type of firms involved, models tested, and evidence of positive consumer and market outcomes. A final report is anticipated by spring 2026. 

What Complyport Can Do to Help 

Complyport offers tailored regulatory support to firms adopting AI in regulated environments. With deep expertise in innovation and compliance, we can assist by: 

  • Benchmarking your AI models to ensure they meet FCA criteria. 
  • Reviewing documentation and deployment plans to support your application. 
  • Advising on engagement strategies with the FCA and risk mitigation approaches. 

Whether you are preparing for FCA feedback, planning your application, or looking to strengthen your AI governance framework, Complyport can support you throughout your AI deployment journey. 

Get in Touch 

Book a consultation with one of our compliance experts today to explore how your firm can benefit from the FCA’s AI Live Testing programme. 

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