The Mills Review helps to reframe what AGBR is really about

Here's the question I keep coming back to after the Mills Review: who owns the consumer's first financial decision?

We've spent the last year treating the Advice Guidance Boundary Review as a proposition-building exercise. Targeted Support went live in April, Simplified Advice follows once CP26/10 lands as a policy statement later this year, and firms have rightly been investing along that continuum. Targeted Support in particular has been a genuinely useful stepping stone, a way to help customers who'd otherwise get nothing, and a first real lesson in delivering personalised help at scale.

But I think Mills changes the frame. What it makes clear is that consumers aren't waiting for any of this. They're already using generative AI for exactly the kind of personal financial questions that sit outside the regulated perimeter. That unregulated shadow isn't a future risk to plan for, it's the baseline we're already operating in, and the AI behind it is getting better faster than most regulated propositions are being built.

So the commercial question shifts. AGBR stops being a compliance workstream to unlock a new segment, and becomes a race for the consumer's first port of call. The moment someone decides what to do with a pension pot, an ISA allowance or an inheritance. Win that moment and you own the relationship. Miss it and you're picking up consumers, if at all, long after someone else has shaped their thinking.

Three things follow from that, and they're worth being blunt about.

1. AGBR propositions have to be AI-enabled by design, not retrofitted. I'd use the Mills language deliberately here: assistive, generative, autonomous, because that's the ladder firms should be mapping their target operating model against.
2. Distribution is quietly losing its power to set firms apart. The advantage is shifting to insight: richer, consented, well-structured data on the customer, and the capability to act on it.
3. The timeline is shorter than it feels, and this is likely what you need to push hardest on. Simplified Advice may be a 2026 policy event, but the consumers those propositions are meant to serve are choosing elsewhere right now.

Realistically that's a twelve-month window to establish the entry point that matters, not a comfortable five-year transition. The question isn't whether to invest in this. It's whether what you build will be ready in time to matter.