Risk · R-116 · Conduct & Customer Outcomes

Poor customer outcomes from AI-driven journeys

An AI-driven customer journey causes foreseeable harm to retail customers, or fails to support their understanding and needs, and outcome monitoring does not detect it.

Severity: High
Audience: Board · Heads-of · Practitioner
Frameworks: PRIN 2A.2 · PRIN 2A.3 · PRIN 2A.9
Responsible AI domain: 07 Fairness & Customer Outcomes
11 Monitoring, Assurance & Incidents
Lifecycle stage: 2 Assess & tier
7 Operate & monitor
Reviewed: 2026-11-11

What it is

This is the general conduct risk. When AI takes over part of a customer journey, such as answering questions, deciding eligibility, setting prices or handling a claim, the organisation remains responsible for what customers experience. For firms regulated by the FCA, the Consumer Duty requires them to act to deliver good outcomes for retail customers: to act in good faith, avoid foreseeable harm, and enable customers to pursue their financial objectives, across product design, price and value, understanding and support. It also requires firms to monitor whether those outcomes are achieved. The risk is that an automated journey performs well on cost and speed while customers are left worse off, and nobody is measuring.

How it happens

Success is defined as containment or cost per contact.
The journey is tested for function and not for what customers understand or decide.
Outcome data for the AI channel is not separated from other channels.
Harm is spread thinly across many customers, each below the level of a complaint.

Why it matters

Customers lose money, cover or access. For a regulated firm, failing to identify and act on poor outcomes is a breach in itself, and the firm is expected to put things right for everyone affected, not only those who complained.

Warning signs

Reporting on the AI channel shows efficiency measures only.
No comparison exists between outcomes in automated and human channels.
Complaints about the channel are rising while its measures stay green.
Nobody is named as accountable for outcomes in the automated journey.

Who owns it

The executive who owns the customer journey is accountable. Compliance sets the monitoring standard. The board reviews outcomes at least annually.

In practice

An insurer's claims assistant settles simple claims in minutes. It also steers customers with complex claims towards a lower cash settlement by presenting it first and describing the alternative as slow. Average handling time falls and satisfaction scores hold. The same pattern generalises to any automated journey judged by what it saves and not by what customers end up with.

Mitigating controls

Primary controls

Customer outcome monitoring Detective: Measures outcomes of AI-driven journeys by customer group. The outcomes customers receive from AI-driven journeys are measured, broken down by customer group and compared with other channels, and poor outcomes are investigated and acted on.

Supporting controls

AI impact assessment process Directive: Identifies foreseeable harm before launch. A structured assessment of an AI system's effect on individuals, groups and society is completed and signed off before deployment, and revisited when the system or its use changes.
Customer remediation for AI errors Corrective: Puts affected customers right. When an AI error is found, all affected customers are identified, told, and put back in the position they should have been in, whether or not they complained.
Feedback and complaints channel for AI Detective: Complaints and reports reveal harm the metrics miss. Users and affected people can report a problem with an AI system easily, and reports are triaged, linked to the system concerned and analysed for patterns.
Pricing fairness review Detective: Covers the price and value part of the outcome. AI-driven prices and offers are reviewed, before use and on a set cycle, for differences between customer groups that cost or risk does not justify.

Framework and clause references

Framework	Clause	Title
FCA Consumer Duty (PRIN 2A)	PRIN 2A.2	Cross-cutting obligations The duty to avoid foreseeable harm.
FCA Consumer Duty (PRIN 2A)	PRIN 2A.3	Products and services outcome Design for the target market.
FCA Consumer Duty (PRIN 2A)	PRIN 2A.9	Monitoring of consumer outcomes Monitoring of outcomes.

Related terms

How to cite

Axiom Verity (2026). Poor customer outcomes from AI-driven journeys. Reference Library, R-116. https://axiom-verity.com/risks/poor-customer-outcomes-from-ai. Reviewed 2026-11-11.

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