On 2 August the deployer obligations under Article 50 of the EU AI Act apply. Firms must disclose when a person is interacting with an AI system, label deepfakes, and flag AI-generated content published on matters of public interest. Most preparation for that date has been run as a technical compliance exercise: an inventory of systems in scope, a review of disclosure wording, a workstream in the second line.
For a UK financial services firm, that framing misses the sharper half of the exposure. The Senior Managers and Certification Regime already requires accountability for each area of a firm's regulated activity to be mapped to a named senior manager, recorded in a Statement of Responsibilities, and filed with the FCA. The regime does not distinguish between a decision made by a human and a decision materially influenced by an AI system. Whichever senior manager owns the relevant decision area owns the Article 50 obligations that now attach to it.
The two regimes therefore converge on a single evidential test, reached from two directions.
The EU regulation asks who is accountable for the deployer's obligations. The domestic regime has already required the answer to be written down, attached to a person, and filed. What a regulator can now ask is narrow: can the named senior manager produce a dated record showing they reviewed the obligation before it applied?
Figure — where the two regimes meet
The failure mode is specific. A firm maps Article 50 readiness to a technical function. Its Statement of Responsibilities names a senior manager. The work is done in one place; the accountability is filed in another. If the named individual holds no dated record of review, the firm carries two accountability gaps that do not agree with each other, and both are visible from documents the regulator already holds.
Closing the gap
Closing that gap is not a documentation exercise after the fact. It requires knowing, for each material AI-assisted decision area, who is named, what they reviewed, when, and whether the date on that record would survive being challenged. That is an assessment of the firm's governance position across accountability, exposure, control, regulation and operational maturity, and it is the starting point of our advisory work.
A Governance Classification Briefing locates a firm's current position and identifies where the evidential gaps sit before a regulator does.
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