Britain's financial regulator has been urged to consider regulation of large language models such as ChatGPT, Claude, and Gemini because of their growing influence on consumer financial decisions, according to a major review published Monday.

The review, commissioned by the Financial Conduct Authority (FCA) and led by Executive Director Sheldon Mills, found that more than a quarter of UK consumers trust AI chatbots for financial advice, with only limited awareness that the protections applying to regulated financial services do not extend to these AI services.

"Personal recommendations by a chatbot could blur the boundary, and continuous, adaptive recommendations may start to look like regulated advice," Mills warned. He recommended that the FCA consider within the next three to six months whether to "secure and adapt" the regulatory perimeter by reviewing the scale, nature and impact of AI models that sit outside it.

The review also highlighted how companies' reliance on a handful of technology providers introduces system-wide risks. Shared reliance on the same models, cloud providers, or technology infrastructure could create correlated behavior, herding, and common points of failure across the financial system.

A recent survey found that 81% of financial firms globally are adopting AI at some level, with 40% at more advanced stages. While most use cases remain concentrated in lower-risk back-office functions, British companies are increasingly deploying AI in customer-facing roles such as complaints handling and investment guidance.

Bank of England Deputy Governor Sarah Breeden signaled for the first time last week the need for bespoke AI regulation, warning that "our frameworks were not built to contemplate autonomous agents, and relying on a human in the loop for all agent actions is unlikely to be realistic."

Jonathan Herbst, global head of financial services at law firm Norton Rose Fulbright, said Mills was not proposing an immediate crackdown but was asking whether the rules need to evolve to reflect how financial services are being delivered — "a big question for policymakers and one that will only become more pressing as AI adoption accelerates."