FCA authorised · FRN 724952 0117 325 0027Quote & buy →
Aipedia: Mortgage brokers
Brokers can use AI in later-life lending and equity release, but the FCA has flagged older and digitally excluded borrowers as a particular risk. These cases involve large sums, family interests and vulnerability, so an error tends to cost more and draw closer scrutiny.
Part of: AI in Mortgage brokers
In short
Later-life lending and equity release advice uses sourcing and research tools, AI-supported needs analysis and increasingly digital journeys. FS25/6 flagged digital exclusion and older borrowers as risks (paras 4.26 and 6.11). The FCA's October 2026 good practice review expects non-AI routes for vulnerable customers and warns against inflexible automated journeys. The Consumer Duty requires firms to avoid foreseeable harm. Later-life cases can attract complaints from family members years later, and insurers may ask more about this work at renewal. PI usually responds to negligent advice, subject to the terms.
Research tools compare lifetime mortgages, retirement interest-only and standard mortgages into retirement, and model how debt grows over time. AI-supported fact-finds and notetakers capture circumstances, health, family wishes and benefit entitlements. Some firms offer digital journeys for the early stages, with AI answering questions or estimating release amounts. The adviser then completes the advice, often with family members involved.
See vulnerable customers for the wider position.
Later-life borrowers are more likely to have characteristics of vulnerability: health conditions, bereavement, cognitive decline or low digital confidence. A tool that works well for confident online users may not notice that a borrower is confused or under pressure from a relative. Projections can look precise while depending on assumptions about house prices and interest that a borrower may not understand. Family members who were not involved may later question the advice, sometimes after the borrower has died.
Automated triage adds another risk. A digital journey that filters out borrowers who do not fit a standard profile, or that is hard to use without help, may exclude the very people who most need advice. FS25/6 raised digital exclusion directly, and the Consumer Duty expects firms to consider the needs of customers with characteristics of vulnerability throughout the journey, not only at the advice stage. Testing the journey with older users, and watching where they drop out, helps show the firm has considered this.
Illustrative scenario: an older borrower uses a broker's online journey, which estimates a release amount and books a call. The AI-supported fact-find records the borrower's wish to help a grandchild buy a home but does not flag that a relative joined the call and answered most questions. The adviser, working from the summary, does not explore whether the borrower understood the effect on their estate or considered alternatives. Years later the borrower's children complain that the advice was unsuitable and the borrower was not supported.
A complaint about unsuitable later-life advice is usually a negligent advice claim, which a policy meeting MIPRU 3.2.4R covers subject to its terms, including Ombudsman awards and defence costs. Because complaints can arrive many years later, continuous cover matters. Insurers may ask what share of business is equity release or later-life lending and how vulnerability is handled, and some may apply specific terms to this work. Answer accurately and describe any AI-supported steps; see does broker PI cover AI mistakes.
Apex arranges PI for mortgage brokers including later-life and equity release advisers, and can help present your vulnerability controls to insurers. See the mortgage broker AI hub.
No specific restriction has been published. FS25/6 flagged digital exclusion and older borrowers as risks, and the FCA's 2026 good practice review expects non-AI routes for vulnerable customers. Existing rules, including the Consumer Duty, apply.
Later-life cases involve large sums, long timescales and borrowers more likely to be vulnerable, and complaints can come from family members years later. Insurers may ask about the volume of this work and how firms handle vulnerability.
They can, if they are accurate and checked. A full record of who attended, what was explained and how the borrower responded is valuable when family members later question the advice. An unchecked summary that misses signs of vulnerability can do the opposite.
The FCA's 2026 good practice review expects firms to offer non-AI routes for vulnerable customers, and FS25/6 raised digital exclusion. A clear human route at every stage is the safest approach.
Tell us about your firm and the work you do. A broker will review how your current PI treats AI-assisted work, or arrange new cover. No fee for a quote. Or call 0117 325 0027.
Start a PI quote Request a callbackApex 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 about how AI is used in the profession and how insurance may respond. It is not legal, regulatory or insurance advice on your circumstances, and it does not guarantee that cover will be available or on what terms.
