Professional indemnity explained
Acre is a mortgage broker platform whose AI tools, according to Acre, transcribe client meetings, compare them with the fact find and check client documents for errors. It matters because the broker usually remains responsible for the advice and the file.
Part of: Mortgage brokers PI insurance
In short
Acre released two AI features on 23 February 2026, initially to a small group of clients: a Meeting Assistant that records and transcribes client conversations and checks them against the fact find, and a Document Checker that classifies documents and flags errors. The FCA has introduced no AI-specific mortgage rules; in FS25/6 it said existing frameworks such as the Consumer Duty and SM&CR can manage many AI risks. The broker, and for appointed representatives the principal, usually remains responsible for suitability. Mortgage broker PI usually responds to advice claims, subject to the policy terms.
Acre is a platform that mortgage brokers use to run cases, from fact find to application. On 23 February 2026, trade press reported that Acre had released two AI features, initially to "a small group of clients". In plain terms:
Separately, on 12 March 2026 Acre announced a full mortgage application with a lender inside its CRM, which Acre says saves "up to 20 minutes per case". That is a workflow feature rather than an AI one, but it means more of the case sits in one system.
What we could not find: Acre's security certifications, where data is stored, whether data is used to train AI models, and any statement that brokers must review AI output. Ask Acre directly and keep the answers on file.
The short answer: there are no AI-specific mortgage rules. The FCA expects firms to manage AI risks through rules that already apply.
| Source | What it says | Status |
|---|---|---|
| FS25/6, Mortgage Rule Review feedback, December 2025 | FCA view (para 4.25): existing frameworks "such as the Consumer Duty and the Senior Manager and Certification Regime" can already manage many AI-related risks | Feedback statement; no AI-specific rules announced |
| FS25/6, respondent views | Para 4.22: AI "should not replace human advisers". Para 4.26: "qualified advisers should review and sign off AI-based recommendations" | Views of respondents, not FCA rules |
| AI and the FCA: our approach | "We do not plan to introduce extra regulations for AI" | FCA policy position, updated 2 October 2026 |
| Mills Review, published 6 July 2026 | FCA review of AI and the future of retail financial services, with recommendations to the FCA | An FCA review, not rules |
We found no AI-specific provision in MCOB. The general MCOB requirements on advice and suitability continue to apply to the advice a firm gives, however it was prepared, as does the Consumer Duty, in force for open products since 31 July 2023. More in mortgage brokers and the FCA AI rules explained.
A mortgage complaint often turns on what the client told the broker and what the broker did with it. A transcript compared with the fact find could help show that the recommendation fitted the client's stated needs and circumstances. It can also work against the firm: if the transcript records something the fact find or recommendation ignored, that gap is now in writing.
The checks Acre describes are prompts for the broker, not conclusions. If the Meeting Assistant flags a mismatch on income, commitments or plans, someone needs to resolve it and record how. See AI notetakers and fact finds and AI affordability checks. Recording also raises transparency duties: clients should be told the call is recorded and processed by an AI tool, as covered in telling clients you use AI.
A document checker can catch a missing payslip or a mismatched name early. It does not make the broker a guarantor of the client's documents. Where a client supplies forged documents and the broker had no reason to suspect them, the loss usually rests with the fraudster, though lenders sometimes bring claims against brokers alleging they should have spotted the warning signs.
The risk shifts if a tool flags a problem and the case goes ahead anyway. A record showing an unresolved alert is unhelpful evidence in a lender claim. Firms should decide who clears Document Checker flags and how that is recorded. See AI document and fraud checks.
Many mortgage brokers trade as appointed representatives. Under FSMA 2000 s39(3), the principal "is responsible, to the same extent as if he had expressly permitted it, for anything done or omitted by the representative" in the business for which it has accepted responsibility. A network that allows an AR to use Acre's AI features is therefore responsible for how they are used, and may set conditions, approved tool lists or file-checking rules.
ARs commonly rely on their principal's PI arrangements, though some are required to hold their own cover. Either way, the network will want to know which AI features are switched on. See adviser networks, AI tools and AR PI and AI and network file checking.
PI usually responds to claims that the firm gave negligent advice or made an error in its professional service, subject to the policy terms, whether or not an AI tool was involved. A data breach involving recordings or client documents is usually a matter for cyber cover. Mortgage broker PI may restrict or exclude some activities, so check that the activities you declare match what you actually do. More in does PI cover AI errors and PI versus cyber.
A client mentions in a recorded meeting that they plan to go part time within a year. The transcript captures it, but the fact find is not updated and the recommended term and payments assume full time income. When the client struggles and complains, the transcript is central evidence. A resulting claim is a professional advice claim and PI usually responds, subject to the policy terms.
An attacker gains access to a broker's account and downloads stored recordings and ID documents. This is a security incident, so cyber cover is usually the first policy to look at.
See also the mortgage brokers AIpedia, the AI tools by profession hub and our mortgage brokers PI insurance guide.
Apex arranges PI and cyber insurance for mortgage brokers; a broker reads every enquiry.
There is no AI-specific FCA rule. In FS25/6 (December 2025), respondents said qualified advisers should review and sign off AI-based recommendations, but that was their view. The FCA's own view was that existing frameworks such as the Consumer Duty and SM&CR can manage many AI risks. In practice, the firm remains responsible for the advice it gives.
PI usually responds to claims arising from the firm's professional advice or service, subject to the policy terms, whether or not a tool was involved. The question is usually whether the advice was suitable, not which software produced the notes. Check your wording for any AI exclusion, condition or endorsement.
Acre says it classifies documents, flags errors at source and reviews paperwork for GDPR and Consumer Duty requirements. It does not transfer responsibility for spotting warning signs. Decide who clears its flags and record how each was resolved, because an unresolved alert can be used as evidence in a lender claim.
We did not find a published statement on this, nor on Acre's certifications or where data is stored. Ask Acre directly before using its AI features on client cases, and keep the answer with your supplier due diligence and data protection records.
Your principal is responsible for your regulated business under FSMA s39(3), so it will usually set the rules. Check with your network before switching features on, and confirm how its PI arrangements treat AI-assisted work.
Tell us which tools your firm uses, what they produce and how output is checked. We will review how your PI and cyber cover respond and what insurers will ask at renewal. No fee and no obligation. Or call 0117 325 0027.
Book a PI programme review Get a PI quoteApex Insurance Brokers Limited is authorised and regulated by the Financial Conduct Authority. Registered in England and Wales, company number 07014570. This page is general information, not advice on your individual circumstances, and it does not guarantee that cover will be available or on what terms.