Mills Review: act fast to benefit from existing advantages

The Mills Review has made it official - customer acquisition is changing and the rise of general-purpose AI tools is shaping consumer decisions.  

But did you know that financial organisations have two key advantages? 

Their existing customer relationships and regulatory advantage could act as a competitive moat. But only if they act quickly.

What is the Mills Review?

Published in July 2026, the Financial Conduct Authority’s (FCA’s) Mills Review investigated how advances in AI have the power to reshape retail financial services. It also made recommendations to the FCA on how it could respond.    

Key findings highlighted in the review include: 

• AI could reshape financial services by as early as 2030. 

   

• Retail financial services are moving from being human-led to offering continuous AI-enabled services. 

   

• Despite 1 in 5 UK adults already being open to AI making decisions on their behalf, consumer adoption of AI finance agents will rely on levels of trust, control, and accessibility. 

Customer interface will become a source of market power

The race is on to dominate the customer interface.

Whoever comes out on top – be it regulated firms, technology platforms, aggregators, or independent agents – will reshape how products are discovered, compared, and sold. Whoever leads on what consumers see will have significant influence over financial decisions and markets. 

The Mills Review warns of a structural shift in retail financial markets. As consumers begin delegating product discovery, comparison, and transactions to AI "agents", traditional financial advisers, product providers and platforms risk being bypassed. 

The threat is not necessarily that AI replaces financial institutions. The threat is that AI inserts itself between organisations and their customers.

The timeline is shorter than many firms assume

The Mills Review argues that firms should plan on the basis that AI-driven disruption could be fully embedded by 2030. 

Historically, the financial services industry has been slow-moving. But with this date looming, the window for preparation is narrow: waiting for regulatory certainty or for the market to mature is itself a strategic risk. 

Thankfully, the review outlines an "Autonomy Spectrum" (ranging from humans as operators to humans as observers of automated AI). This is designed to help organisations start preparing for the transition immediately.

AI is already influencing financial decisions

A staggering 9 million UK adults - or 16% of consumers - are already using AI tools for financial tasks (source: Mills Review). 

Traditional channels are no longer the sole sources of customer acquisition and decision-making. As general-purpose large language models are gaining popularity and becoming part of everyday life, tools such as ChatGPT, Claude, and Gemini are already helping consumers make financial decisions. 

However, these AI tools operate outside the traditional regulatory perimeter, creating new questions about influence, accountability and consumer protection.

Why regulated firms still hold the advantage

Although timelines are growing shorter, these organisations have a head start - they possess assets that are difficult for an AI company to replicate. The trusted customer relationships, an established brand, distribution channels and valuable client data already exist.  

Financial organisations also operate within a regulatory framework that the Mills Review largely views as capable of supporting AI-enabled services through existing principles such as Consumer Duty and SMR. 

Those strengths create a competitive moat, but only if they are used to deliver AI-enabled experiences before others own the interface.

The AI opportunity

The next five years won't be defined by who adopts AI first. The winners are unlikely to be the firms with access to AI alone, as increasingly capable models will be available to everyone. 

The advantage will come from combining AI with trusted customer relationships, strong governance, regulatory credibility and proprietary customer data. Firms that embed AI into customer journeys now have an opportunity to strengthen their existing moat before new intermediaries establish control of the relationship. 

At EV, we’re seeing more firms explore how AI-led customer engagement can work alongside proven stochastic forecasting and modelling capabilities. This gives organisations room to innovate while preserving the governance, transparency and security their customers expect. 

The question isn't whether to do AI. It's how to do it safely and speedily: grounded in a forecasting engine and trusted customer data. That's what we're built for.

How EV supports retail financial services 

EV's modular technology – powered by one robust data source – enables organisations to develop customer journeys that are intuitive from the first touchpoint to the last. Explore our full range of capabilities.