The FCA's Mills Review just made the case for AI distribution in financial services

Last updated: 13 July 2026
On 6 July 2026 the UK's financial regulator published the Mills Review, "AI and the future of retail financial services," and confirmed the shift WaniWani has been building for: by 2030, consumer financial journeys become agent-led, and whoever controls the AI interface influences which products consumers see, how those choices are ranked, and where the value is captured. For any bank, insurer, or lender, that is a distribution question, and the FCA just put it in writing.
What is the Mills Review?
The Mills Review is a landmark report the Financial Conduct Authority published on 6 July 2026, led by Sheldon Mills, the FCA's Executive Director for Consumers and Competition. The FCA describes it as the first review of its kind initiated by a financial regulator anywhere in the world. It sets out four systemic shifts that will reshape retail financial services by 2030: AI transforms how firms operate, consumer journeys become agent-led, AI reshapes competition and market power, and AI amplifies fraud and cyber risk.
"Artificial intelligence will transform financial services by 2030. It creates significant opportunities for consumers, firms and the wider economy," said Sheldon Mills, Executive Director for Consumers and Competition at the FCA.
Why does the Mills Review matter for distribution?
It matters because a regulator, not a vendor, is now saying the customer relationship is moving into the AI layer. The review's second shift is that consumers will increasingly delegate to AI applications that act on their behalf, moving "beyond offering information and recommendations towards trusted AI agents that can act continuously for consumers within agreed limits."
The consumer research underpinning the review, conducted by Yonder for the FCA with 5,026 UK adults in April 2026, shows this demand is real but front-loads the recommendation stage. Willingness to use AI declines as autonomy rises: 36% would use AI that reviews their finances and makes recommendations, 30% would let it act with permission each time, and 20% would let it act autonomously within pre-set goals. In other words, the largest, nearest-term demand is for AI that finds, compares, and recommends, exactly the layer that decides which providers get seen.
When people stop visiting your site and start asking an assistant to search, compare, and recommend, the assistant becomes the channel. That is not a marketing nuance. It is where the sale now starts.
Who controls the AI interface controls the customer
The review's third shift is the one every distribution leader should read twice. On competition and market power, the FCA writes that "control of the AI-mediated customer interface may become a major source of market power." It continues: "As consumers rely on agents to search, compare and transact, the owner of that AI layer may influence which products are visible, how choices are ranked and where value is captured, shifting the customer relationship away from financial services providers."
That is the whole thesis of AI distribution, stated by the regulator. If you do not have a presence inside the AI conversation, someone else decides whether your product appears, in what order, and at what price. The firms that own that layer capture the customer. The firms that do not become a line item in someone else's ranking.
This is already happening, not a 2030 forecast
The Mills Review looks to 2030, but the channel is live now. For early-moving direct and digital-native insurers, roughly 20% of new business is already coming from LLM-sourced customers. That traffic converts 4-5x better than traditional search, because the buyer arrives at the point of decision rather than the top of a funnel.
Insurance is where consumers most want this. In the FCA's consumer research, reviewing insurance was the single most attractive AI use case of any tested, ahead of switching products, borrowing, and saving: 46% would use AI to review their insurance and make recommendations, versus 24% for AI that moves money between accounts, the least popular. Consumers want AI to help them shop and compare in exactly the categories WaniWani serves.
The market has already repriced around it. WaniWani built the first-ever quoting insurance app on ChatGPT for Tuio, and after ChatGPT's insurance features rolled out, more than $26B in insurance-broker market cap was wiped as investors recalculated who owns the customer when the interface changes. The Mills Review is the regulatory confirmation of a move the market has already started making.
What financial services firms should do about it
The review is encouraging about the opportunity, and it is candid that "access to useful and reliable AI services, trust and control will ultimately define consumer uptake and outcomes." Firms that want to be on the right side of that have four things to work through:
- Find out how AI already talks about you. Ask ChatGPT, Claude, and Gemini what the best provider is in your category. If a competitor is named and you are not, that is your baseline.
- Build a presence in the channel, not just monitoring of it. Knowing you are invisible does not fix it. A distribution app on the MCP protocol lets your product answer questions, generate quotes, and capture leads inside the assistant, where the buyer already is.
- Measure it like a real channel. Default web analytics capture only ~0.5-3.5% of AI-sourced traffic, while declarative tracking shows 15-20%, a 4-6x underestimation. You cannot make the case for a channel you cannot see.
- Treat compliance as first-class. The FCA is explicit that consumers must be able to "oversee, understand and challenge AI-driven decisions." In regulated distribution, the guardrails and monitoring inside the AI conversation are the product, not an afterthought.
What is agent-led distribution?
Agent-led distribution is the shift from customers browsing your website to customers delegating the search, comparison, and transaction to an AI assistant that acts on their behalf. In the Mills Review's framing, consumers move from using AI for information toward trusting AI agents to manage and optimise their financial lives within agreed limits. The provider's job changes from owning a website to being visible, quotable, and transactable inside the assistant.
Frequently asked questions
What is the Mills Review?
The Mills Review is a report the UK's Financial Conduct Authority published on 6 July 2026, titled "AI and the future of retail financial services." Led by Sheldon Mills, it sets out four systemic shifts reshaping the sector by 2030 and is described by the FCA as the first AI review initiated by a financial regulator globally.
What does the Mills Review say about AI and competition?
It warns that control of the AI-mediated customer interface may become a major source of market power. As consumers rely on agents to search, compare, and transact, the owner of that AI layer can influence which products are visible, how choices are ranked, and where value is captured, shifting the customer relationship away from financial services providers.
What are agent-led consumer journeys?
Agent-led journeys are financial journeys where consumers delegate to AI applications that act on their behalf. The Mills Review describes a shift from AI offering information and recommendations toward trusted AI agents that act continuously for consumers within agreed limits, managing and optimising their financial lives.
How many people are ready to use AI for financial services?
In Yonder's research for the FCA (5,026 UK adults, April 2026), willingness fell as AI autonomy rose: 36% would use AI that reviews finances and recommends, 30% would let it act with permission, and 20% would let it act autonomously within pre-set goals. Demand is real but concentrated at the recommendation stage, not full delegation.
Which financial task do consumers most want AI to help with?
Reviewing insurance was the most attractive use case in the FCA's consumer research: 46% would use AI to review their insurance and make recommendations, the highest of any category tested. The least popular was AI moving money directly between accounts, at 24%. Consumers want help shopping and comparing more than they want AI holding the controls.
What should a bank or insurer do about the Mills Review?
Check how AI assistants describe your category today, build a presence inside the AI conversation rather than only monitoring it, measure AI as a real channel using declarative tracking, and treat in-conversation compliance and oversight as core. The firms that own the AI interface capture the customer; the rest get ranked by someone who does.
WaniWani is the AI distribution infrastructure platform. We build your presence inside ChatGPT, Claude, and Gemini, where your customers already ask, and give you the analytics and compliance monitoring to run it as a channel. Request a demo.