AI Regulation Tracker · UK (BoE / PRA / FCA) · Report

What does FS2/23 say about AI in banking?

Published Oct 26, 2023 · Last reviewed Aug 26, 2026

FS2/23, published on 26 October 2023, summarises the 54 responses to DP5/22 and records the industry consensus that a regulatory definition of AI would not be useful and that the UK should rely on principles-based, technology-agnostic regulation. Respondents asked for periodically updated 'live' guidance, more coordination between regulators, and clearer expectations on third-party models and data. The statement contains no policy proposals.

DocumentFS2/23Feedback Statement 2/23: Artificial Intelligence and Machine Learning
Issued byBank of England, Prudential Regulation Authority, and Financial Conduct Authority
TypeReport
StatusFinal
PublishedOct 26, 2023
Applies toAll PRA- and FCA-regulated firms (summary of consultation responses; no policy proposals)
Official sourcebankofengland.co.uk
Use casesAI governance (general) · Model risk management · Third-party & vendor AI · Fair lending & discrimination

What are the key points of FS2/23?

  • 54 responses; industry bodies were almost a quarter and banks a further fifth of respondents.
  • A regulatory definition of AI was judged unhelpful; a risk-based or characteristics-based approach was preferred.
  • Respondents wanted 'live' regulatory guidance and best-practice examples updated as capabilities change.
  • The regulatory landscape for AI was seen as complex and fragmented, especially data regulation; more domestic and international alignment requested.
  • Consumer outcomes, fairness and bias were identified as the key focus for regulation and supervision.
  • Increasing use of third-party models and data was flagged as a concern needing more guidance.
  • The AI Public-Private Forum was cited as a template for ongoing engagement — later realised as the 2025 AI Consortium.

What did FS2/23 change for banks?

FS2/23 turned DP5/22's question into the UK's settled answer: no AI rulebook, supervise through existing frameworks, monitor via surveys and industry forums. Every later UK document — SS1/23's AI sub-principle, the FCA's 2024 AI Update, the 2026 letters to government — cites this feedback as the basis for staying technology-agnostic.

What did FS2/23 conclude about AI regulation in the UK?

That existing principles-based frameworks largely suffice, a regulatory definition of AI is not useful, and regulators should focus on consumer outcomes, third-party risk and coordination rather than new AI-specific rules.

Did FS2/23 introduce any requirements?

No. It is a summary of responses and explicitly states it contains no policy proposals.

DateDocumentStatus
Jul 14, 2026HM Treasury Financial Services AI Adoption Plan (Jul 2026)Financial Services AI Adoption PlanFinal
Jun 5, 20262026 BoE/FCA AI surveyThe Bank of England and FCA's 2026 AI SurveyFinal
May 15, 2026BoE/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 resilienceIn force
Apr 1, 2026BoE response to Treasury Committee AI inquiry (Apr 2026)Response to TSC inquiry report on AI in financial servicesFinal
Apr 1, 2026BoE/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 innovationFinal
Jan 28, 2026DSIT/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 StateFinal

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