In this episode, Annie Garcia and Rob Healey break down the “Accountability Crisis” facing UK Financial Services in 2026. As the FCA moves from principles to aggressive enforcement, Annie and Rob explore why “the AI did it” is no longer a legal defense. They dive deep into Agentic AI governance, SM&CR personal liability, and how firms are using Formiti’s “Zero-Gap” audits to stay ahead of the February 2026 funding and compliance deadlines.
Key Takeaways
What is the “Accountability Gap” in 2026 Financial AI? In 2026, the Accountability Gap refers to the disconnect between autonomous AI actions and Senior Manager liability. Annie and Rob explain that under the UK Data Use and Access Act 2025, firms must bridge this gap using Human-in-the-Loop protocols and Algorithmic Explainability to satisfy FCA Consumer Duty.
- Agentic AI Risks: Why autonomous trading agents require a physical “Kill-Switch” audit.
- SM&CR Liability: How Rob defines the “Reasonable Steps” a Senior Manager must document to avoid personal fines in 2026.
- The AI-BOM: Using an “AI Bill of Materials” to identify “Shadow AI” within your infrastructure.
- The “Secret Weapon” “Reasonable Steps”In 2026, the FCA’s legal “test” for Senior Managers is whether they took “Reasonable Steps” to prevent AI failure.