One annual review, start to finish: what AI prepares and what the adviser decides

48% of UK advisers now say their firm is using or bringing in AI for meeting notes, up from 25% a year earlier, and 40% for suitability work, up from 11%, according to NextWealth research for Fidelity published in September 2026. The gap by size is wide: 72% of firms with six or more advisers use it for meeting notes, against 31% of smaller firms.

There is no equivalent Irish survey yet, but the same tools are arriving in Irish practices under a different rulebook: the Central Bank's revised Consumer Protection Code, in force since 24 March 2026. The clearest way to see where AI fits, and where it must not, is to follow one piece of work from start to finish.

The example below is illustrative: an annual review for Declan, a 58-year-old company director with an executive pension, a PRSA and a life policy, who plans to retire at 63.

The meeting is recorded, and Declan is told at the start. The Code already requires this for recorded phone calls (Regulation 63), and it is the right standard for any meeting an AI note-taker listens to.

That first line matters more than it looks. Where an adviser explains a product out loud, the Code requires a record of that explanation in, or with, the Statement of Suitability (Regulation 18(7)). It is easy to miss when a note is written from memory a week later, and hard to miss when it is drafted from the meeting itself.

The Code asks firms to endeavour to have the client certify the accuracy of the information gathered about them (Regulation 16(13)). A pre-filled fact-find makes that easier, not harder: Declan checks a short list of highlighted changes instead of a blank form.

AI does not decide what is suitable. It writes up the adviser's decision clearly and consistently. The Code requires information to be clear, accurate and in plain language, and that applies to an AI draft exactly as it does to a letter typed by hand.

What the adviser does that AI cannot

Across the six steps, AI gathers, drafts, checks and chases. The adviser listens, judges and recommends: noticing that Declan hesitated when income in retirement came up, deciding what is most suitable for him, and standing behind that advice with a signature. That is what clients pay for, and it is the part of the week that paperwork keeps crowding out.

Is this allowed?

Yes. In its guidance on the revised Code, the Central Bank says the Code is technology neutral: whatever technology a firm uses, the obligations of the Code must be met. In practice that means:

• The firm stays responsible. Any activity carried out on its behalf by someone else must comply with the Code (Regulation 119), and that includes an AI provider.
• Records are kept for six years (Regulation 117), so file notes and recordings need a home you control, with a clear retention period.
• In its 2026 Regulatory and Supervisory Outlook, the Central Bank said firms deploying AI need clear accountability, human oversight of decisions and the ability to explain them, with governance in proportion to the risk.
• Under the EU AI Act, the high-risk list covers areas such as credit scoring and the pricing of life and health insurance. Drafting file notes and suitability letters is not on it.
• Under GDPR, the Data Protection Commission advises checking where personal data goes and whether your AI provider keeps or reuses it. Protection fact-finds often include health information, which needs extra care.

A system built like the example above keeps every recommendation with the adviser and leaves a clearer record than most practices have today.

Where to start

Start with meeting notes. They touch every client, and every later step depends on them being right. Once the notes are trusted, the fact-find and the suitability draft follow naturally.

This article is general information, not legal or regulatory advice.