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Consumer Duty, the FCA and client data
Recording client meetings with an AI note taker: what SYSC 10A requires, what to tell the client, and a script and six-point note check for a small advice firm
What SYSC 10A requires of a meeting record, what the ICO says to tell clients before recording, and a script and six-point check for an AI-drafted note.
An advice firm can record a client meeting and let software draft the note, provided three things are true. The client was told before the recording started. The finished note contains what the FCA's record-keeping rule lists. An adviser has read it and corrected it.
The forum thread where paraplanners ask which note taker to use (371 views and 7 comments on 1 October 2026) compares accuracy and says nothing about what to tell the client or what the note must contain.
Free tool
Meeting recording notice maker
Enter the client, the meeting and how to reach you. The email tells the client the meeting will be recorded, that software drafts the note for the adviser to check, and the date the record is kept until.
- Send it before the meeting, and still say the script at the start, before the recording is switched on.
- If your retention policy is longer than five years, change the period and the date in the text.
- Check that your privacy notice says how the recording tool is used.
- If the client declines, the handwritten note still needs the date and time, the place, who attended, who asked for the meeting and any instruction.
The rule this rests on: SYSC 10A.1.11R and 10A.1.14R; ICO advice for small organisations on recording online meetings. A draft to check and adapt, not legal advice. Regulated work: the adviser, and the compliance function where the firm's procedures require it, reviews and signs every client-facing document and every suitability decision; the AI assistant prepares, checks and chases, it never advises.
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Who is already doing this
Fidelity's IFA DNA study, reported on 9 September 2026, found 72% of advisers in firms with six or more advisers using or bringing in AI for meeting transcription and notes, against 31% in firms with five or fewer. No sample size was given.
One forum member describes the gain: "What used to take them 1 to 2 hours to do post meeting now takes 20-30mins." Another describes the risk: the tool "can also put information in the notes which is wrong or invites misinterpretation."
Taking the middle of each range, a firm holding 8 client meetings a week spends 8 × 90 minutes, or 12 hours, writing notes by hand. At 25 minutes each that is 200 minutes, or 3 hours 20 minutes. The difference is 8 hours 40 minutes a week, on one member's account of one tool.
What the FCA rule says
SYSC 10A.1 covers conversations that relate to activities in financial instruments such as arranging deals, dealing and managing investments, including conversations meant to lead to a transaction that never happens (SYSC 10A.1.1R and 10A.1.8R). Ask compliance which of the firm's meetings fall inside it.
| Rule | What it says |
|---|---|
| SYSC 10A.1.6R | A firm must take all reasonable steps to record relevant telephone conversations and keep copies of relevant electronic communications |
| SYSC 10A.1.9R | A MiFID optional exemption firm serving solely or mainly retail clients may keep a written minute or note of a telephone conversation instead, showing the date and time, who took part, who initiated it, and the client order: price, volume, type and when it will be transmitted or executed |
| SYSC 10A.1.16R | For relevant face-to-face conversations the firm must record, in a durable medium, the date and time, the location, the attendees, who initiated the meeting, and the same details of any client order |
| SYSC 10A.1.11R and 10A.1.12AR | Clients must be told before any service is provided that conversations will be recorded, and that a copy is available on request for 5 years to the client and 7 years to the FCA |
| SYSC 10A.1.14R | Records must be given to the client on request and kept for five years, or up to seven where the FCA asks |
The FCA rule requires notice. It does not ask for the client's permission, though a firm can choose to ask, and the script below does.
What data protection adds
The Information Commissioner's Office puts it in one sentence in its advice for small organisations on recording online meetings: "Before recording, you should tell people why you're recording, what you'll use it for, and how long you'll keep it."
The ICO has also answered a question about an AI tool used for meeting recordings and notes. Where the tool supports work the organisation already does, it need not find a new lawful basis. It should update its privacy notice to say how the tool is used, and it "must check that the outputs are accurate, and take steps to correct any inaccurate information."
Client meetings often include health. Article 9 of the UK GDPR lists "data concerning health" among the special categories, so a recording of a conversation about a diagnosis is special category data, and so is the transcript. Our guide to AI and client data in an advice firm covers the account and contract conditions that apply before a tool handles it.
The script
Put one line in the meeting invitation:
We record our meetings and use software to draft the written note, which your adviser then checks. We keep the record for at least five years and you can ask for a copy. If you would prefer us not to record, tell us and we will take notes by hand.
Say this at the start, before the recording is switched on:
Before we begin, I would like to record this meeting. Software turns the recording into a draft note, and I read and correct that note myself so your file is accurate. We keep it for at least five years, as our regulator requires, and you can have a copy whenever you ask. If you would rather I did not record, I will take notes by hand. Are you happy for me to start?
Change the five years to match your firm's own retention policy if it is longer. Then, once it is recording, say the date, where you are and who is in the room. Software cannot note a location nobody mentioned.
The six-point check on the draft note
Do this the same day.
- Date and time of the meeting are stated.
- Location is stated, or the note says it was a video call.
- Every person present is named, including a partner or relative who sat in.
- The note says who asked for the meeting.
- Any instruction is recorded with the price, the amount, the type of order and when it will be placed. If no instruction was given, the note says so.
- The adviser has read the whole note against their own memory, corrected it, and added their name and the date of the check.
File the corrected note and the recording on the client record. If the client declined recording, the handwritten note needs the same first five points.
A report drafted from the note still has to pass the suitability report file check.
Who signs
The adviser, and compliance where the firm's procedures require it, reviews and signs anything a tool drafts, and that includes the meeting note. Overlyft
can set up an AI assistant to run the first five points on a draft and list what is missing for the adviser to complete. This page is general information, not legal, regulatory or financial advice.
Short answers from this page
Do I have to tell a client before recording a meeting with an AI note taker, and how long must the record be kept?
Yes. Where SYSC 10A applies, clients must be told before any service is provided that conversations will be recorded. SYSC 10A.1.14R requires the record to be given to the client on request and kept for five years, or up to seven where the FCA asks. The adviser has to check an AI-drafted note before it goes on file.
Source: FCA Handbook SYSC 10A.1.11R, 10A.1.14R and 10A.1.16R; ICO advice on recording meetings
What does a note of a face-to-face client meeting have to include under SYSC 10A?
SYSC 10A.1.16R says the record of a relevant face-to-face conversation must include the date and time of the meeting, its location, who attended, who initiated it, and the details of any client order: price, volume, type of order and when it will be transmitted or executed. An AI-drafted note needs checking for each of these before it goes on file.
Source: FCA Handbook SYSC 10A.1.16R, read 1 October 2026
Every short answer for financial advisers and mortgage brokers
Where this comes from: FCA Handbook SYSC 10A.1.1R, 10A.1.6R, 10A.1.9R, 10A.1.11R, 10A.1.12AR, 10A.1.14R and 10A.1.16R (version dated 23 October 2025), read 2026-10-01; ICO, advice for small organisations on recording online meetings, and ICO innovation advice, previously asked questions (AI tool for meeting recordings and notes), read 2026-10-01; UK GDPR Article 9(1) on legislation.gov.uk, read 2026-10-01; Fidelity Adviser Solutions IFA DNA study via Professional Paraplanner, 9 September 2026; The Big Tent forum threads on AI note takers, read 2026-10-01. General information, not legal or regulatory advice.
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.



