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Consumer Duty, the FCA and client data
Can a financial adviser or mortgage broker use ChatGPT, Claude or Copilot for client work? Business plan prices on 1 October 2026, what each vendor says about training on your data, and three prompts with no client in them
Yes, for routine work that is not advice. Business seats cost £13.80 to £22.50 a month on 1 October 2026. Each vendor's training terms, and three prompts.

Yes, for routine work that is not advice, on a business plan, with nothing in the prompt that identifies a client, and with the adviser reading what comes back. On 1 October 2026 a business seat cost between £13.80 and £22.50 a month, and the FCA's own page on AI said it does not plan extra rules.
What this is, and is not. A desk check of four vendors' price pages and data terms, read in a browser on 1 October 2026. We did not trial the products and we do not rank them.
What a business seat costs
| ChatGPT Business | Claude Team | Microsoft 365 Copilot Business | Google Workspace Business Standard | |
|---|---|---|---|---|
| Per seat per month, paid for a year | £15 | £18 | £13.80, shown as reduced from £16.10 | £11.80 on a one-year commitment |
| Per seat, paid monthly | £18 | £22.50 | Offered; figure not read | Not read |
| VAT | Not stated on the page | Included at 20% | Not included | Not stated on the page |
ChatGPT Business and Claude Team start at two seats. Copilot Business is an add-on to a Microsoft 365 business plan; Microsoft also sells Business Standard with Copilot as one licence at £18.10 a user a month, paid yearly, before VAT.
Claude's page shows dollars until its scripts run, then pounds with the line "Prices include 20% VAT". £18 with VAT is £15 before it (18 ÷ 1.2). ChatGPT's page shows £15 without saying whether VAT is in it, so ask before you compare the two.
Four seats for a year
Take a firm buying four seats: two advisers, a paraplanner and an administrator.
| Plan | Sum | A year |
|---|---|---|
| ChatGPT Business, annual billing | 4 × £15 × 12 | £720, VAT not stated |
| Claude Team, annual billing | 4 × £18 × 12 | £864 including VAT |
| Copilot Business add-on | 4 × £13.80 × 12 | £662.40 plus VAT, which is £794.88 with it |
| Google Workspace Business Standard | 4 × £11.80 × 12 | £566.40, VAT not stated |
Copilot works inside Word, Excel, Outlook and Teams, and its figure sits on top of the Microsoft 365 licences the firm already pays for. The Google figure buys email and documents as well, so it compares only if you would move your email.
What each vendor says about training on your data
| Vendor | What its own page says about a business plan, in our words |
|---|---|
| OpenAI | Business data is not used to train its models by default. If the firm opts in, for example by sending feedback, what it shares may be used. On the same price page the personal plans show training as on, with an opt-out. |
| Anthropic | The Team plan lists no model training on your content by default. The commercial terms, effective 17 June 2025, say Anthropic "may not train models on Customer Content". |
| Microsoft | Prompts, responses and data reached through Microsoft Graph are not used to train the foundation models behind Copilot. |
| Workspace content is not reviewed by people, or used to train generative AI models outside your own domain, without permission. |
Three of the four qualify the promise with "by default" or "without permission". The setting belongs to whoever administers the account, so one named person should hold it. A personal login is a different contract.
Training is one condition of six. The rest are in our guide to AI and client data in an advice firm.
What the FCA has published
Three pages on fca.org.uk, read the same day:
- "AI and the FCA: our approach", last updated 13 February 2026, says: "We do not plan to introduce extra regulations for AI." It relies on existing frameworks and names two: the Consumer Duty, and senior manager accountability under the SM&CR.
- The AI in financial services page reports that 75% of firms have adopted some form of AI and 84% have an individual accountable for it.
- The Mills Review, published on 6 July 2026, makes seven priority recommendations to the FCA Board. They are addressed to the regulator, and none is a rule for firms.
So nothing forbids a chat assistant, and nothing excuses what it writes.
Three prompts with no client in them
None needs a name, a date of birth, a policy number, an address or a health detail.
1. Plain wording. Paste your own standard paragraph under it.
Rewrite the paragraph below for a reader with no financial background. Keep every number and date exactly as written. Add no fact, opinion or recommendation. List any term you could not make simpler.
2. Reading a public paper. Check each paragraph number against the paper afterwards.
Below is the text of an FCA consultation paper. List each proposed change that affects a firm with fewer than ten advisers, with the paragraph number it comes from. Where you cannot see a paragraph number, write "not found".
3. An office procedure. The timetable is the one in our letter of authority chase guide.
Draft a one-page procedure for chasing a letter of authority at 10, 15 and 20 working days. Use numbered steps and say who does each one. Mark every assumption you made with the word CHECK.
Read every output before it is used.
The job we would not hand over
The recommendation, and the paragraph of the suitability report that says why it suits this client.
COBS 9.4.7R requires the report to explain why the firm has concluded that the recommended transaction is suitable, having regard to the information the client provided. A general assistant can write that paragraph only if the fact-find is pasted in, which is the client data the prompts keep out. It would then produce tidy reasons the adviser never had. The reasoning has to be the adviser's own. The suitability report file check tests that it is on the page.
Recording a meeting has its own rule: see recording client meetings with an AI note taker.
Who signs
Overlyft is not a chat assistant and is not in these tables. It prepares review packs and drafts reports on the firm's own template for the adviser to check.
The adviser, and compliance where the firm's procedures require it, reviews and signs anything a tool drafts. This page is general information, not legal, regulatory or financial advice.
Short answers from this page
How much do ChatGPT Business, Claude Team and Microsoft 365 Copilot cost per user in the UK?
On 1 October 2026 the vendors' own pages showed ChatGPT Business at £15 a seat a month billed annually or £18 monthly, with VAT not mentioned; Claude Team at £18 or £22.50, including 20% VAT; and the Microsoft 365 Copilot Business add-on at £13.80 a user a month paid yearly, before VAT. Four seats for a year come to £720, £864 and £662.40.
Source: ChatGPT, Claude and Microsoft 365 Copilot pricing pages, read in a browser on 1 October 2026
Do ChatGPT, Claude and Copilot train on a firm's data on their business plans?
Each vendor's own terms, read on 1 October 2026, say not by default. OpenAI does not train on business data unless the firm opts in. Anthropic's commercial terms say it may not train models on customer content. Microsoft says prompts, responses and data reached through Microsoft Graph are not used to train foundation models. Personal ChatGPT plans show training as on, with an opt-out.
Source: OpenAI enterprise privacy page; Anthropic Commercial Terms of Service; Microsoft Learn, Data, Privacy, and Security for Microsoft Copilot; read 1 October 2026
Every short answer for financial advisers and mortgage brokers
Where this comes from: ChatGPT pricing page (Business tab) and OpenAI enterprise privacy page; Claude pricing page (Team tab, UK render) and Anthropic Commercial Terms of Service effective 17 June 2025; Microsoft 365 Copilot for business page (UK) and Microsoft Learn, Data, Privacy, and Security for Microsoft Copilot; Google Workspace pricing page (UK) and Generative AI in Google Workspace Privacy Hub; FCA, AI and the FCA: our approach (last updated 13 February 2026), the FCA's AI in financial services page, and The Mills Review (6 July 2026); FCA Handbook COBS 9.4.7R; each read in a browser on 1 October 2026
AEO Lookup editorial team
We write practical guides for people who run small UK firms, and we check every fact against its source on the date shown. Read how we review, or tell us if something has changed.



