Built for industries where “move fast and break things” is an enforcement action.
Quad builds agentic systems for regulated enterprises. Every workflow is auditable, every decision explainable, and every process runs inside a compliance envelope regulators can read.
BNPL is becoming regulated.
The FCA window is weeks away.
The FCA's Temporary Permission Registration regime for BNPL opens 15 May 2025 and closes hard on 1 July 2025. From that date, every UK BNPL firm needs demonstrable compliance infrastructure — Consumer Duty evidence, creditworthiness assessment, and a model risk trail — or it cannot legally lend. This is not a future compliance horizon. It is a deadline in weeks.
Most BNPL firms built on speed. Underwriting is a model score, affordability is a checkbox, and the audit trail is whatever the database captured. That was fine when BNPL was unregulated. Under the FCA regime it is an enforcement action. Layered AI is the fastest path from where you are to where the FCA expects you to be — because we build the compliance architecture and the evidence substrate simultaneously, not sequentially.
- •Creditworthiness and affordability assessment with a reproducible decision trail
- •Consumer Duty outcome evidencing per customer journey
- •Model risk documentation to SS1/23 standard
- •Vulnerable customer identification and escalation
- •An audit substrate a regulator can examine — not reconstruct after the fact
Compliance gap audit
Map your current decisioning stack against FCA CONC and Consumer Duty. Identify the evidence gaps a regulator examination would find.
Layered AI evidence substrate
L01 evidence schema deployed. Every creditworthiness and affordability decision begins writing a regulator-readable record from day one of registration.
L03 Consumer Duty codification
FCA PRIN 12 and CONC affordability rules encoded as machine-checkable policy. Same-day policy updates as FCA guidance evolves.
Registration evidence pack
FCA Temporary Permission submission pack assembled from the evidence substrate. Model risk documentation to SS1/23. Ready for examination.
Registration is the floor.
The roadmap unlocks compounding value.
Every BNPL firm that survives the registration deadline faces the same competitive dynamic: compliance is now table stakes, and the firms that turn it into a product capability win. The Layered AI architecture you build for FCA registration is the foundation for five value cycles that compound over the following 24 months.
From ad-hoc evidencing to continuous Consumer Duty output.
Every credit decision automatically produces a Consumer Duty outcome evidence record — without a project team assembling it. FCA examination becomes a query, not a fire drill. L01 substrate begins accumulating the portfolio-level insight that feeds the next cycle.
FCA-compliant affordability assessment in seconds, not minutes.
Replace the static scorecard with an L04 agent that retrieves live Open Banking, ONS income indices, and Companies House data — assessed by an L03 policy engine running codified CONC rules. Faster decisions, lower impairment, and a complete model risk trail for PRA SS1/23. Approval latency drops from minutes to seconds without sacrificing the evidence depth the FCA now requires.
Automated vulnerability identification before a customer reaches collections.
An L04 agent monitors portfolio behaviour against L03 codified FCA Vulnerable Customer Guidance — surfacing early-stress signals and triggering proportionate interventions. Compliant collections journeys, reduced write-offs, and a documented Duty of Care record per customer that closes FOS complaints before they escalate.
The evidence substrate becomes a living risk model — feeding AI fine-tuning loops.
18 months of structured decisioning data in L01 now powers automated review loops: model performance evaluated continuously against real outcomes, regulatory data ingested from FCA publications and ONS in real-time, and a closed learning cycle that feeds fine-tuning of your decisioning models. The regulatory feedback loop that was previously a quarterly risk committee becomes a continuous agentic process.
The same Layered AI stack re-parameterised for EU Consumer Credit Directive 2 (CCD2) jurisdictions.
The EU Consumer Credit Directive 2 harmonises BNPL regulation across 27 member states — with affordability assessment and information disclosure obligations that mirror the FCA regime. The L03 policy modules and L01 evidence substrate built for UK FCA registration re-parameterise for CCD2 without an architectural rebuild. European expansion with a compliance posture already designed for it.
Each cycle builds on the same L01 substrate. You do not rebuild. You extend.
The BNPL firms that treat FCA registration as a compliance cost will spend the next three years catching up. The firms that treat it as an architectural investment will have a model risk trail, a real-time risk intelligence layer, and a cross-border compliance posture that their competitors are still building.
Underwriting at agent speed. Audit at regulator depth.
FCA Handbook (PRIN, COBS, SYSC) • PRA SS1/23 model risk • Consumer Duty • SMCR • EBA guidelines • AML / KYC • DORA • ICO • UK GDPR
Loan origination & underwriting
Application intake, KYC, affordability, suitability, decision and evidence pack — orchestrated end-to-end with Consumer Duty codified.
KYC & perpetual due diligence
Live Companies House, OFSI, EU sanctions & PEP feeds. Continuous monitoring, not periodic refresh.
SAR triage & AML investigations
Alert prioritisation, evidence assembly, narrative drafting — bounded by codified rules for filing thresholds.
Consumer Duty evidencing
Outcome evidence assembled automatically per customer journey — ready for FCA inspection without a project team.
Claims that settle in minutes. With evidence the regulator can read.
FCA Handbook (ICOBS) • PRA Solvency II • Consumer Duty • ABI codes • FOS expectations • Lloyd's minimum standards • vulnerable customers
Submission & binder automation
Broker-submitted risks parsed, enriched, pre-priced and routed inside underwriting authority. Hours, not weeks.
Claims FNOL to settlement
Multi-channel intake, coverage check, triage, reserve and settlement — with vulnerability flags surfaced automatically.
Fraud-network detection
Cross-claim graph analysis, sanctions screening, organised-fraud pattern matching — running on every claim, every time.
Reinsurance & treaty ops
Bordereaux reconciliation, treaty allocation, cession calc — agents that close the month in a day, not a fortnight.
The agentic trade system that HMRC and the EC already recognise.
HMRC CDS • Union Customs Code • UK Tariff • CHIEF transition • OFSI & EC sanctions • WCO HS • FTA rules of origin • EU VAT • CBAM
Classification & tariff calc
HS / commodity classification with full HMRC tariff retrieval, citation, and confidence score. Every decision auditable.
HMRC & EC integrations
Direct submission into CDS and EC member-state systems. Formal recognition. Multiple jurisdictions live.
Origin, valuation & sanctions
WCO and FTA rules codified. Live OFSI / EC sanctions screening on every shipment. No manual list lookups.
Excise, VAT & duty reconciliation
Period-end VAT reconciliation, duty deferment, drawback claims — agents that close the books and the audit.
Agentic systems where patient safety sets the bar.
MHRA • EMA • ICH-GVP • ICH-GCP • HIPAA-aligned • NICE • UK GDPR (special category data) • SaMD principles • EU MDR
Clinical trial operations
Site activation, monitoring, deviation logging, query management — bounded by GCP and protocol-specific rules.
Pharmacovigilance case intake
Multi-channel intake, MedDRA / WHO-DRUG coding, seriousness assessment, E2B(R3) generation, gateway submission.
Regulatory submission drafting
CTD modules, Module 3 sections, briefing books — assembled from authoritative source data with citations.
NHS reimbursement workflows
NICE submissions, payer dossiers, value cases — with structured links to evidence and clinical data.
Margin-positive agents. Not a brand-damaging chatbot.
UK GDPR • GDPR • Consumer Rights Act • Consumer Protection Regs • Digital Services Act • competition law • PCI DSS • PSD2
Merchandising & pricing agents
Category-aware pricing actions inside competition-law guardrails. Promotion compliance built in.
Returns & dispute resolution
Returns assessed against statutory rights and policy. Disputes resolved with citation. Refunds within authority.
Supplier & PIM enrichment
Product data normalisation across suppliers. GS1 codes, dimensions, safety attributes — cited.
Loyalty & personalisation
Personalisation that respects consent boundaries — with the evidence trail UK GDPR expects.
Supply chains, warranty, homologation — under audit-grade agents.
UNECE / WP.29 type approval • UK VCA • EU CSRD / CSDDD • UK Modern Slavery Act • OPSS • REACH • CBAM • ISO / TS 16949
Supplier risk & ESG diligence
CSRD, CSDDD and Modern Slavery diligence as a continuous agentic process — not an annual survey.
Warranty & recall orchestration
VIN-level recall execution, OPSS notification, dealer comms — with regulator-readable evidence packs.
Production planning copilots
Demand-sensing and constraint-aware planning agents that respect bill-of-materials and supply commitments.
Type-approval & homologation
UNECE/WP.29 dossier assembly, VCA submission prep, derivative-model variants — built from cited evidence.
See your process as an agentic system
Book a 30-minute session. Bring your most painful compliance or operations workflow — we'll prototype an agentic solution live, on your data.