Before an AI note-taker joins your next client meeting

Advisers like note-takers for a good reason. The write-up after a client meeting is slow, and the tool does it in minutes. But a meeting note in an advice firm isn't just a record. It feeds the suitability file, it may be the only evidence of what the client said about their circumstances, and it contains some of the most sensitive personal information the firm holds.

The FCA has said it won't write extra rules for AI and will "rely on existing frameworks" (FCA, AI and the FCA: our approach, updated 13 February 2026). For a note-taker, the existing frameworks are the Consumer Duty, the senior managers regime and UK GDPR. Each one asks a question before the tool joins a meeting.

What should an advice firm check before using an AI note-taker?

Where the recordings and notes go and whether they're used for training, that there's a written processor contract, that clients are told and asked, that an adviser checks the note before it goes on file, and that a named senior manager has approved the tool. That's five things, and they fit on one page.

1. Where do the recordings go?

Ask the provider, in writing. Where recordings and transcripts are stored, how long they're kept, who can access them and whether they're used to train the provider's models. UK GDPR expects a written contract with any processor handling personal data on your behalf, and for a tool that records client meetings a data protection impact assessment may be needed too. If the note-taker came bundled with your video call software, these questions still apply, and the answers may be different from the ones for the main product.

2. Does the client know, and have they agreed?

Tell clients before the meeting, not at the start of it. A sentence in the client agreement explaining that you use an AI note-taker, and a question at the top of each meeting asking whether they're content. If they'd rather not, the adviser takes notes the old way. Under the Consumer Duty, the FCA expects firms to communicate in a way that meets customers' information needs, and a client who later discovers their meeting was transcribed by software hasn't had that.

3. Who checks the note?

The adviser, before it goes on file. A note-taker summarises, and summaries lose things. If the client mentioned an inheritance in passing, a change in health, or that they'd rather not take risk with a particular pot, the summary may have kept it or may not. The adviser was in the room. A rule that no AI-generated note goes on file until the adviser has read and corrected it keeps the suitability record yours.

The FCA's approach page says firms must communicate in a way that meets customers' information needs and support them appropriately. A suitability report built on an unchecked note that got the client's objectives wrong fails that test however the note was produced.

4. Who approved the tool?

A named senior manager. The FCA's approach page says its rules "emphasise accountability for senior managers and are relevant to the safe use of AI". If you were asked who approved the note-taker, there should be a name, a date and a record of what was checked. In a small firm that's the compliance officer or a partner, and the record is a page in the approved tools register.

5. What goes into the next tool along?

Note-takers increasingly offer to send the summary on: into the back office, into a CRM, into an email to the client. Each handoff is another place client data goes. Decide which connections are switched on and which aren't, and write it down. The default should be off until someone has checked where the data ends up.

What about the clients who don't want it?

Some won't, and they're entitled to that. Make it easy to say no, and make sure the adviser's own notes are as good as the tool's. A client who objects is exercising exactly the choice you're meant to give them.

I lead a live AI rollout inside a regulated business, so I've had to answer these five questions myself rather than in theory. They take an afternoon to settle. Not settling them means client meetings being recorded by a tool nobody has checked.

What should a firm do this month?

Find out whether a note-taker is already switched on in your meeting software, get the provider's data answers in writing, add the sentence to your client agreement, and name the senior manager who owns it.

• Check your video call and meeting tools for AI features that are already on.
• Send the data questions to the provider and keep the answers with your tools register.
• Add the client agreement sentence and agree the question advisers ask at the start of meetings.
• Record the senior manager's approval, and the rule that advisers check every note.

My AI governance kit for financial advice firms has the client agreement wording, the approved tools register, the tool assessment and a supplier checklist, mapped to the FCA's approach. If you'd rather I set it up with your team, that's the team AI rollout.

Sources

1. 01FCA, AI and the FCA: our approach, first published 8 September 2025, last updated 13 February 2026. fca.org.uk/firms/innovation/ai-approach
2. 02FCA, AI Update, 2024. fca.org.uk/publication/corporate/ai-update.pdf
3. 03ICO, guidance on AI and data protection, contracts with processors, and data protection impact assessments. ico.org.uk

This article is general information, not financial, legal or regulatory advice. Check the FCA's current guidance and speak to your compliance adviser about your firm.