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.
OFFICIAL TEXT: bankofengland.co.uk ↗ · FINAL · UK (BOE / PRA / FCA)
| Document | FS2/23 — Feedback Statement 2/23: Artificial Intelligence and Machine Learning |
| Issued by | Bank of England, Prudential Regulation Authority, and Financial Conduct Authority |
| Type | Report |
| Status | Final |
| Published | Oct 26, 2023 |
| Applies to | All PRA- and FCA-regulated firms (summary of consultation responses; no policy proposals) |
| Official source | bankofengland.co.uk ↗ |
| Use cases | AI 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 technology-neutral model scope, 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.
| Date | Document | Status |
|---|---|---|
| Sep 30, 2026 | Bailey: Frontier AI and the Question of Governance (Sep 2026) — Frontier AI and the Question of Governance — Governor Andrew Bailey | Final |
| Sep 2, 2026 | FCA multi-firm review: Frontier AI and cyber resilience (Sep 2026) — Frontier AI and Cyber Resilience | In force |
| 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 |
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