FS25/5, published 9 September 2025, is the FCA's feedback statement on its proposal, first announced on 29 April 2025, to run AI Live Testing — a programme in which firms deploy AI systems in live UK markets with tailored regulatory and technical support and jointly evaluate fairness, accuracy, consumer outcomes and operational resilience. The first cohort (NatWest, Monzo, Santander, Scottish Widows, Gain Credit, Homeprotect and Snorkl) began in October 2025 with technical partner Advai; a second cohort of eight firms including Barclays, Experian, Lloyds Banking Group, UBS and GoCardless was announced 21 April 2026, with an evaluation report due in Q1 2027.
| Document | FCA FS25/5 — FS25/5: AI Live Testing |
| Issued by | Bank of England, Prudential Regulation Authority, and Financial Conduct Authority |
| Type | Report |
| Status | Final |
| Published | Sep 9, 2025 |
| Applies to | FCA-authorised firms with mature AI proofs of concept ready for live deployment (voluntary programme) |
| Official source | fca.org.uk ↗ |
| Use cases | Customer-facing chatbots · Credit scoring & underwriting · AI governance (general) · Generative & agentic AI |
What are the key points of FCA FS25/5?
- AI Live Testing sits inside the FCA AI Lab (launched October 2024) alongside the Supercharged Sandbox for earlier-stage experimentation.
- Targets firms with mature proofs of concept ready for controlled live deployment, not research projects.
- Evaluation focuses on evaluation frameworks, live monitoring, governance and risk management, and consumer outcomes.
- First cohort (from October 2025) use cases: debt resolution, financial advice, customer engagement, complaints handling, spending and saving guidance.
- Second cohort applications ran 19 January to 24 March 2026; testing from late April 2026; eight firms including Barclays, Experian, Lloyds Banking Group (Scottish Widows), UBS, GoCardless, Coadjute, Aereve and Palindrome.
- Testing concludes by end-2026 with an FCA evaluation report in Q1 2027.
- The BoE/PRA told government in April 2026 that firms saw the FCA's Live Testing and Supercharged Sandbox as sufficient, so no separate PRA sandbox is planned.
What did FCA FS25/5 change for banks?
Rather than write AI rules, the FCA is generating supervisory expectations by watching real deployments. The published evaluation framework and the Q1 2027 report are likely to become de facto good-practice benchmarks for customer-facing AI in UK retail banking.
What is FCA AI Live Testing?
A programme in which authorised firms deploy AI in live UK markets under FCA supervision with technical partner Advai, jointly evaluating fairness, accuracy, consumer outcomes and resilience. Cohort one started October 2025; cohort two in April 2026.
Which banks are in FCA AI Live Testing?
Cohort one included NatWest, Monzo, Santander and Scottish Widows; cohort two includes Barclays, Lloyds Banking Group (Scottish Widows), UBS, Experian and GoCardless.
| Date | Document | Status |
|---|---|---|
| Jul 14, 2026 | HM Treasury Financial Services AI Adoption Plan (Jul 2026) — Financial Services AI Adoption Plan | Final |
| Jun 5, 2026 | 2026 BoE/FCA AI survey — The Bank of England and FCA's 2026 AI Survey | Final |
| May 15, 2026 | BoE/FCA/HMT joint statement on frontier AI and cyber resilience (May 2026) — The Bank, FCA and HM Treasury joint statement on Frontier AI models and cyber resilience | In force |
| Apr 1, 2026 | BoE response to Treasury Committee AI inquiry (Apr 2026) — Response to TSC inquiry report on AI in financial services | Final |
| Apr 1, 2026 | BoE/PRA plan for safe AI innovation (Apr 2026) — Letter from Sarah Breeden and Sam Woods to the Chancellor and Secretaries of State on enabling safe AI innovation | Final |
| Jan 28, 2026 | DSIT/DBT strategic letters to regulators (Jan 2026) — How will regulators enable safe AI-powered innovation: joint letter from DSIT Secretary of State and DBT Secretary of State | Final |
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