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Zahid Bilgrami, CEO of Mortgage Brain, makes the case that AI procurement in UK broker networks has become a compliance liability sitting inside an IT budget line, and the resulting mismatch is exactly what regulators will find first. Anchored in UK Finance’s 2026 board-level AI guidance, the procurement checklist covers six pressure points: cost pass-through clauses, data residency and sub-processor transparency, output consistency under audit, appropriate model selection, operational resilience, and Consumer Duty exposure. The core provocation is that no one inside most firms is clearly accountable for any of it.
What this means for your business
The firms most exposed here are not the ones that haven’t deployed AI yet. They’re the ones that signed a vendor agreement when AI was still a demo feature and haven’t revisited it since. If your broker network or financial services stack runs on a tool built on top of a general-purpose model like GPT or Gemini, your supplier is a reseller of someone else’s infrastructure, and every upstream pricing decision by OpenAI or Google passes through to your contract unless a clause in writing says otherwise. Most don’t.
The consistency question is the sharpest edge in the piece. Large language models are probabilistic by design, meaning the same input can produce different outputs across separate queries. In a regulated advice context, that’s not a UX quirk; it’s an audit failure and a Financial Ombudsman exposure waiting to be triggered. Bilgrami’s ask, that suppliers guarantee identical outputs for identical inputs and produce an auditable reason trail behind every decision, is the right standard, and the uncomfortable reality is that most off-the-shelf AI tools in financial services cannot meet it today. Vendors who can’t answer that question in a contract clause, not a sales call, are telling you something.
The Consumer Duty angle reframes what looks like a vendor management problem into a board accountability one. Under the FCA’s Consumer Duty, the obligation to deliver fair outcomes and fair value sits with the firm, not the technology supplier. If an AI tool embedded in the advice process generates biased recommendations, unjustifiable rejections, or becomes unaffordable to member firms because of mid-contract price hikes, the network carries that exposure. The vendor doesn’t. The checklist is most useful as a forcing function for the conversation that didn’t happen at procurement, and the right moment to run it is before the next renewal, not after the first FCA review.
Based on reporting from The AI procurement checklist for broker networks, originally published 2026-07-17 05:49:00.
