FCA finds listing sponsors using AI for research and drafting, with human review

The Financial Conduct Authority has described how UK listing sponsors are using AI, finding a range of research and drafting applications but no fully automated sponsor process in the small sample it examined. Its findings appear in Primary Market Bulletin 67, published on 4 November.[1]

All the firms in the sample had access to enterprise AI tools, although none required staff to use them. Uses varied across sponsor work and included research, comparisons and drafting support. The sample is a supervisory snapshot rather than a measure of adoption across every UK sponsor.[1]

The FCA emphasised that sponsor firms remain responsible for their work when AI assists it. Human review of the output therefore matters to the decision submitted or advice given, rather than merely to whether a tool has been approved for use.[1]

The bulletin discusses controls around enterprise deployment, including data ownership and whether confidential inputs can be used to train a provider’s models. It also treats record keeping as a matter of context: the significance of an AI-assisted draft or note depends on the work it supports, rather than on a rule that every prompt must always be retained.[1]

Separately, the bulletin introduces a consultation on proposed technical-note changes, with responses due by 9 December 2026. That consultation should not be confused with a new rule mandating or prohibiting AI use by sponsors. The AI section reports observed practice and the responsibilities that continue to apply.[1][2]

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