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Rathi's AI pivot: the FCA bets on competition as the new prudential frontier

FCA chief Nikhil Rathi has used a techUK speech to recast the regulator's posture on AI, signalling that competition dynamics and system-wide resilience will increasingly drive supervisory attention as agentic systems and tokenisation scale. For senior leaders in banks, asset managers and insurers, the message is that accountability for AI-driven outcomes will not move with the technology, and concentration risk is now firmly on the conduct regulator's agenda.

Nikhil Rathi's speech at techUK on 24 June marks the most explicit shift yet in how the FCA intends to supervise AI in regulated firms. More than 80% of financial services firms are already adopting AI, according to studies cited by the FCA chief executive, and the question now, he said, is one of scale (FCA). The framing matters: Rathi is no longer treating AI as an emerging risk to be mapped, but as an active force reshaping market structure faster than the rulebook governing it.

Two scaling vectors anchor the speech. The first is agentic systems, which Rathi described as moving beyond summarisation and detection toward coordination and transaction, including liquidity management and trading workflows in wholesale markets (FCA). The second is tokenisation, where the FCA approved Baillie Gifford alongside Bank of New York Mellon on Monday to launch the UK's first natively tokenised authorised fund (FCA). The combination is significant: programmable infrastructure plus autonomous agents implies a market structure where execution, settlement and decision-making compress into a single technical stack. The regulatory question of who is accountable when an agent transacts becomes the central conduct question of the next cycle.

The more consequential signal sits in Rathi's framing of competition and resilience as linked concerns. As AI reshapes markets and increases interconnection, he said, understanding how competition is evolving, and where that may impact resilience, will become more important than ever (FCA). Read alongside the FCA's parallel competition action this week, where 11 commodity futures day traders offered a £1m ex gratia payment to the Crisis and Resilience Fund to settle concerns about coordinated trading and information sharing (FCA), the direction is clear. The FCA is positioning competition law as a live supervisory tool, not a dormant one, and intends to apply it to the concentration risks AI adoption is already creating in model providers, cloud infrastructure and data vendors.

For senior leaders, the practical implications are sharper than the speech's tone suggests. Boards that have framed AI governance primarily around model risk and consumer outcomes now need to add a third dimension: dependency on a small number of upstream providers, and the resilience consequences when those providers move in concert. Rathi was explicit that investors will be wary to delegate important decisions to systems they do not understand, and that accountability for regulated activities and outcomes must remain clear (FCA). That sentence will be quoted back at chief executives in supervisory letters. It means human oversight design, audit trails for agent decisions, and contractual clarity with AI vendors are no longer engineering concerns, they are board-level accountabilities.

The tokenisation track adds urgency. With banks already piloting tokenised deposits to reduce friction and fraud in processes like home buying (FCA), and the Baillie Gifford approval setting a live precedent, asset managers and custodians without a credible tokenisation roadmap will find themselves answering harder questions from distribution partners within twelve months.

The implication for executives is straightforward. The FCA has told the market it will measure AI adoption through the lens of competition and concentration, not just conduct. Firms that cannot articulate their upstream dependencies, and the resilience plan when those dependencies fail simultaneously, should expect that gap to surface in the next supervisory cycle.

What this reveals

Rathi's speech exposes a governance gap that most financial services boards have not yet closed: AI accountability has been framed internally as a model risk and consumer outcomes problem, while the regulator is now treating it as a competition and systemic resilience problem. The assumption that adopting mainstream AI tooling is a defensive, low-controversy choice fails the moment supervisors read concentrated dependence on a handful of model, cloud and data providers as a market structure risk that firms are individually accountable for. Other leadership teams may wrongly believe their AI governance is mature because model risk committees exist, without noticing that their upstream provider map, their agentic use cases, and their tokenisation roadmap have never been tested against the FCA's evolving conduct and competition lens.

Questions accountable leaders should ask

  • 01Can we name, at board level, the specific upstream AI, cloud and data providers our regulated activities depend on, and describe what happens to accountability if two of them move in concert?
  • 02Where in our business are agentic systems already moving from summarisation into coordination, transaction or liquidity decisions, and who is the accountable individual under SM&CR for those outcomes?
  • 03Have we tested our AI and tokenisation plans against the FCA's competition and resilience framing, or only against internal model risk and consumer duty frameworks?
  • 04If a supervisor asked us tomorrow to evidence how we monitor concentration risk in our AI supply chain, what would we actually show them?
  • 05Are the assumptions underneath our AI governance still the ones we made 12 months ago, and who inside the firm is authorised to challenge them?

What accountable leaders should do now

  1. 1Commission a board-level review that reframes AI governance around three dimensions, not two: model risk, consumer outcomes, and upstream provider concentration and resilience.
  2. 2Map every material AI, cloud, data and tokenisation dependency against named accountable executives under SM&CR, and identify the points where an agentic system is making or influencing regulated decisions.
  3. 3Pressure-test the firm's current AI and tokenisation roadmap against the FCA's competition and resilience lens, using external intelligence rather than internal consensus, before the next supervisory engagement.
  4. 4Rewrite the board's AI reporting pack so that concentration risk, agentic decision boundaries and accountability chains are standing items, not annexes.
  5. 5Establish a standing mechanism to detect divergence between the firm's stated AI posture and evolving supervisory expectations, so the next Rathi-style shift does not require a reactive scramble.

Explore the practical guide

This guide identifies where board-level strategic thinking typically diverges from what supervisors actually care about in financial services, and how to spot and close those gaps before they become enforcement problems. After reading, you will be able to audit your own board papers and strategy documents for the specific blind spots regulators notice.

Read the guide

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