The regulatory pile-up
UK: FCA Supervisory Statement 1/23 on AI in financial services + PRA SS3/23 on model risk management both require firms to evidence AI usage controls. EU: MiCA Article 41 + DORA both require operational resilience documentation for AI-mediated decisions. US: SEC 2025 AI guidance to investment advisers expects "comprehensive AI activity records". Each regulator wants similar evidence; the natural answer is a unified audit layer.
Why fintech AI is high-stakes
Investment recommendations, credit decisions, fraud screening, customer-facing chatbots — all AI-mediated and all subject to regulatory scrutiny. The penalty exposure is enormous: FCA fines for inadequate controls have hit £100M+; SEC AI-disclosure fines started in 2025 (e.g. Delphia $400k, Global Predictions $175k). The "no audit trail for AI" finding is no longer a paper-tiger risk.
Specific FCA SS1/23 controls receipts satisfy
SS1/23 §3.1.4: maintain records of AI model decisions. Receipts log the model + the decision + the supervising human. §3.2.7: evidence of human oversight at appropriate decision points. Receipts capture reviewer_human_id and decision timestamps. §4.1.2: monitoring for model drift. Anomaly detection flags atypical model use. The mapping is documented in the FCA-specific evidence pack.
DORA operational resilience scope
DORA Article 6 requires ICT risk management including AI dependencies. Article 28 requires third-party-risk register including AI providers. The receipt feed becomes both the operational ICT log (Article 6) and the third-party-usage record (Article 28). One source feeds two regulatory views.
Operational scenario: credit decisioning
Your AI-assisted credit decision system uses Claude to evaluate edge cases. Without receipts: when the regulator asks "why was application X declined?", you have only the engineer's recollection. With: the receipt shows the prompt + model + supervising-human + decision. The regulator gets a verifiable record; the candidate gets a defensible answer.
Operational scenario: anti-money-laundering
AI-flagged transactions get reviewed by analysts. The receipt captures the AI flag, the analyst's human_id, the decision (escalate / clear), the timestamp. Your MLRO has the full chain; the regulator's next audit gets it in the evidence pack. SAR filings reference the receipt IDs for chain of custody.