Building the UK's agentic financial services infrastructure: creating the future, building on the past? Part one
'Originally written for and published by UK Finance'
The past month has seen a swift but aligned shift in UK policy thinking on agentic AI in financial services.
The FCA's Mills Review and two HM Treasury documents (the AI Adoption Plan and the Modernising Payment Services Regulation consultation) – all published within weeks of each other - together articulate a vision for the future of UK financial services and a novel global opportunity to set a distinctly British approach to agentic finance. This two-part blog post examines the shared themes and invites stakeholders to participate in this unique opportunity to shape policy in this key area.
A novel agentic payments infrastructure
Across all three reports, there is a shared conviction that the UK is well placed to lead the world in devising and leveraging our existing payments infrastructure to create a unified set of architecture, protocols and standards for agentic commerce.
The HMT consultation states plainly: “The Government wants the UK to be at the forefront of the global development of agentic payments” and sees this area as "a genuine opportunity to lead the world". The AI Adoption Plan frames agentic payments as "a near-term practical proxy for a broader class of emerging autonomous financial systems" which can build on the UK's existing high levels of digital adoption.
The Mills Review provides the strategic context, observing that “the technology exists and jurisdictions are addressing the questions that underpin agentic finance”. It also notes that two competing stacks - one for agentic commerce and payments, another for enterprise identity - are being developed commercially but are not currently interoperable, leaving a clear gap for a country willing to set those unified standards.
The UK’s combination of an outcomes-based regulatory philosophy, existing digital money infrastructure, forthcoming Open Banking framework and the government’s willingness to set a global standard show that this is not an abstract ambition. It is a call sign for the industry to take on the mantle.
This briefing looks at how this could be achieved based on existing regulatory policy and the new areas required to fulfil the ambition.
Existing regulatory perimeters to agentic AI and the remaining gaps
All the reports identify the flexibility of UK law and regulation to cater for agentic commerce but with novel gaps emerging.
HMT's Modernising Payments consultation asks specifically whether an agentic future will require "provisions relating to authentication and consent of payments transactions, and liability for unauthorised payment transactions" to be updated.
Mills finds that whilst "the overall regulatory framework remains sound" and can flex to accommodate many AI applications, although when agents move from supporting action to taking action, existing frameworks may come under strain.
The AI Adoption Plan aligns by noting that, in complex value chains, "existing legal and regulatory frameworks do not yet provide sufficient clarity on responsibility and consumer protections". It calls for a trust framework built on three pillars: legal and liability frameworks, Know Your Agent protocols plus authentication and governance standards.
This convergence is mirrored in the recent work of the UK Jurisdiction Taskforce (UKJT), which published its final Legal Statement on Liability for AI Harms also in July 2026.
The UKJT concludes that English law, as a "well developed flexible common law system", can address AI-related harms through existing principles of negligence and duty of care. Ultimately, legal liability must rest with legal persons (human or legally recognised entities) since AI has no separate legal personality.
The three reports demonstrate that there is a need to adapt our current legal and regulatory concepts in order to facilitate an agentic payment infrastructure. Solutions may come from legislation or case law but much will need to be driven by policy, the regulators and indeed industry itself.
Authors: Fiona Ghosh, Partner; Patricia Wade, Expertise Counsel
