FCA SS1/23 Model Risk Management

The FCA’s Supervisory Statement SS1/23 sets binding expectations for how UK-regulated firms must manage the risks arising from models, including AI and machine learning systems used in credit decisions, market risk, and customer-facing applications. Published in May 2023, SS1/23 requires firms to maintain a comprehensive model inventory, conduct rigorous pre-deployment validation, and implement ongoing performance monitoring throughout each model’s lifecycle.

Critically, SS1/23 demands that firms document model limitations, assumptions, and validation outcomes in a form that can be presented to the FCA on request. For AI models this means capturing training data lineage, hyperparameter choices, fairness testing results, and the chain of approvals from model owner to senior accountable person. Under SMCR, a named Senior Manager must attest to each model’s fitness for purpose. Firms without automated audit infrastructure typically rely on spreadsheets and email threads, creating material gaps that the FCA has cited in recent supervisory reviews.

Audital’s cryptographic audit trail captures every model event, decision, and governance action in an immutable, RFC 3161-timestamped log that satisfies SS1/23 documentation requirements automatically. Evidence packages can be exported on demand for regulator submission.

How Audital Addresses SS1/23

Audital was designed specifically around the SS1/23 framework. Every model registered in Audital receives an automatically maintained lifecycle log, SMCR accountability assignment, and validation evidence store. The platform generates SS1/23-aligned evidence packages with a single click, reducing regulator-ready documentation from weeks to minutes.