In her address at Merchant Taylors’ Hall on 17 September 2025, Jessica Rusu, the FCA’s Chief Data, Information and Intelligence Officer, set out a comprehensive programme of initiatives underpin the regulator’s growth and innovation agenda. The speech, “Regulating for growth – the future is now”, presented four central pillars: strengthening crypto oversight, advancing artificial intelligence supervision and experimentation, supporting scaling firms, and developing Open Finance through smart data infrastructure.
The first area concerns the cryptoasset sector. Rusu confirmed that the FCA has launched a consultation proposing minimum standards for crypto firms. The draft rules focus on two areas familiar from mainstream financial regulation: operational resilience and systems and controls for financial crime. The consultation also asks whether the Consumer Duty should apply to crypto businesses, extending requirements for firms to deliver “good outcomes” for retail clients into this new sector. A further question is how consumer complaints should be handled, including whether the remit of the Financial Ombudsman Service should extend to disputes with crypto providers. The consultation is open into late 2025, and the FCA has indicated that final rules will be delivered in 2026.The second theme, and the most extensively developed in the speech, is the regulation of artificial intelligence. The FCA’s AI Live Testing programme was formally launched following consultation and industry feedback earlier in the year. The regulator’s Feedback Statement FS25/5 sets out the background and scope of the initiative.
The FCA received 67 responses to its engagement paper, including 15 from regulated firms and 52 from wider stakeholders such as consultancies, academics, trade associations and specialist technology providers. Across these responses there was broad support for the proposal. Respondents highlighted that proofs-of-concept (PoCs) frequently stall due to uncertainty over regulatory expectations and the absence of clear benchmarks for fairness, safety and robustness. By providing a structured supervised environment, Live Testing was seen as a means to build transparency, trust and accountability, while allowing firms to progress deployments that would otherwise remain in pilot stages.
The FCA’s feedback statement also set out the challenges that firms anticipate. Respondents flagged the complexity of deploying AI in production use cases, noting risks such as model drift, the need for continuous monitoring, and the difficulty of ensuring explainability in systems that may rely on opaque model architectures. Data quality, provenance and representativeness were recurring themes, as were concerns about governance, accountability for third-party models, and the costs of participating in live trials.Industry Responses
Suggestions from industry included the development of standardised benchmarks, outcome-focused monitoring of consumer impacts, and the publication of anonymised case studies to promote shared learning across the market. The FCA confirmed that AI Live Testing with the first cohort of firms will begin supervised deployment in October 2025. Each cohort will run for approximately twelve months, after which the FCA will publish a public evaluation report, ensuring that insights from the trials are available to the wider industry.
In parallel with Live Testing, the FCA has announced the launch of a Supercharged Sandbox, developed in partnership with NVIDIA. This new facility will provide firms with access to advanced compute power, enhanced datasets and specialist tooling to accelerate experimentation with AI. The sandbox is designed to support use cases across financial crime, financial inclusion, digital identity and Open Finance. Taken together, the Live Testing and Sandbox programmes mark an impressive expansion of the FCA’s role as a convenor and facilitator in AI deployment, moving beyond supervisory oversight into active support for responsible innovation.
The third pillar of the speech was scaling. Rusu announced the creation of a new Scale-Up Unit, to be developed jointly by the FCA and the Prudential Regulation Authority (PRA). The Unit will provide a dedicated channel of engagement for high-growth regulated firms that encounter unique challenges as they expand their operations, systems and governance structures. To inform the design and focus of this new function, the FCA is convening a Scale-Up Summit in late September, bringing together firms that have already reached “unicorn” status and others at the frontier of growth. The purpose of the summit is to identify specific regulatory or operational barriers that impede scaling, and to ensure that regulatory support structures are adapted to the realities of rapidly growing businesses
The fourth area covered in the speech was Open Finance. Rusu confirmed the launch of the Smart Data Accelerator, a programme intended to build the infrastructure and evidence base for data-sharing across financial services beyond payments. The Accelerator will begin with experiments in SME finance and mortgages and will include a series of TechSprints later in 2025 to test solutions in practice. The FCA underlined that meaningful consumer consent, secure API infrastructure and the preservation of trust are prerequisites for any Open Finance framework. To that end, the FCA is working closely with the Information Commissioner’s Office to ensure that data protection and governance expectations are aligned across regimes. The Smart Data Accelerator builds on the outcomes of the FCA’s March 2025 Open Finance Sprint, which examined practical use cases and identified early priorities for experimentation
The speech concluded with an affirmation of the FCA’s regulatory philosophy. Rusu emphasised that the FCA remains committed to a principles-based and outcomes-focused approach, anchored in frameworks such as the Consumer Duty and the Senior Managers and Certification Regime. These principles will continue to apply regardless of the technology in question, ensuring accountability and consumer protection even as the regulator moves to actively support innovation.
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