Njagi’s central argument is that commercial enthusiasm for AI is creating a gap between what looks impressive in a product demonstration and what actually serves customers at scale. “Products can look impressive in a demonstration but struggle when customers start using them at scale,” she said. “The test is whether they solve a meaningful problem, make the customer’s experience simpler and have the operations behind them to deliver reliably.”

The regulator’s review did not name firms but outlined a pattern: financial services businesses are deploying AI tools with insufficient clarity about the customer problem being addressed, and with oversight frameworks that have not kept pace with the capabilities being introduced. Operational resilience, a concept the FCA and Prudential Regulation Authority have embedded in formal rules for several years, featured prominently as an area where AI deployments are lagging.

The findings carry weight in a regulatory environment that is moving quickly. The FCA has signalled a pro-innovation stance on AI but has been equally clear that the Consumer Duty, which came into full force in 2023, requires firms to demonstrate good outcomes for retail customers. That creates a compliance obligation, not merely a design preference, to understand what customers need before committing engineering resource to building.

Njagi sets out five principles that she argues produce technology products built to last. These cover prioritising genuinely important customer problems over fashionable technology trends; investing in operational foundations rather than surface-layer design; managing complexity internally so customers experience simplicity; building teams with genuine ownership of outcomes; and maintaining the strategic flexibility to change direction as regulation, technology and customer behaviour shift.

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