FCA Consumer DutySM&CRUK GDPR / ICOEquality Act 2010PRA SS2/21

AI Governance
Gap Analysis

A confidential, self administered assessment for UK credit unions. Evaluate your AI governance position against FCA Consumer Duty, SM&CR accountability, UK GDPR, Equality Act obligations, and outsourcing controls.

Why this matters now (April 2026)

The FCA's Consumer Duty is fully in force for all products and services. The FCA and PRA have confirmed that SM&CR already applies to AI governance. Senior Managers are personally accountable for AI systems in their area of responsibility. The ICO is actively supervising automated decision making. Credit unions using AI in lending, fraud detection, or member services face material regulatory risk without robust governance.

10 MIN
Full Assessment

Confidential AI Governance Scorecard

A comprehensive 24 question assessment across six regulatory sections. Generates a detailed board ready results report with section scores, maturity ratings, and recommended actions. Includes a dedicated section on practical vendor assurance for credit unions relying on third party AI tools.

  • 24 questions across 6 regulatory sections
  • Section by section scoring and maturity level
  • Regulatory context for every question
  • Practical vendor assurance guidance
  • Downloadable board ready results report
  • Save and resume at any time
UK GDPRSM&CRConsumer DutyEquality ActVendor Assurance
3 MIN
Rapid Assessment

2026 AI Governance Pulse Check

A condensed 10-question specialist assessment targeting the most critical areas of regulatory exposure as at April 2026. Ideal for a quick governance health check or as a starting point before the full scorecard.

  • 10 specialist questions
  • Regulatory context for each question
  • Maturity level and downloadable report
  • Completes in approximately 3 minutes
UK GDPRSM&CRConsumer DutyEquality ActOutsourcing

Most Common AI Governance Gaps for UK Credit Unions

Credit Decisioning

Automated loan approval modules from third party FinTech providers. Key risks: bias against protected characteristics, lack of explainability, and no human review process for borderline decisions.

AML and Fraud Monitoring

AI driven transaction monitoring tools. Key risks: over reliance on vendor assurances, inadequate change management when models are updated, and failure to document the human oversight process.

Member Service Chatbots

Automated member service tools. Key risks: crossing the advice and guidance boundary, failure to disclose AI use to members, and inadequate escalation paths when a member's query requires human judgement.

Not sure where to start?

Speak with a Clarendon specialist who can help you understand your credit union's AI governance obligations and where to focus first.

Book a 15 Minute Call

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