Most brokerages now have an AI tool somewhere in the workflow. Fewer can say, in one sentence, who approved it and what the rule behind that approval is.
I tried to build the answer as a table, and the first draft was wrong in the same place most AI guidance is wrong: it treated every firm as the same kind of firm. Where you sit in the regulatory structure changes which rules apply to you. So what follows is written for the firm types it actually covers, and it says so.
Records. A firm must keep "orderly records... sufficient to enable the FCA to monitor the firm's compliance" (SYSC 9.1.1R). This applies to a firm that is not a common platform firm. Any AI-generated note that becomes part of the file is a record you must be able to produce.
Compliance. A firm must maintain adequate policies and procedures covering its "managers, employees and appointed representatives" (SYSC 6.1.1R). The AI tool's use sits inside the compliance framework. It is not outside it.
Client communications. Retail customers must be communicated with in a way which is "clear, fair and not misleading" (PRIN 2A.5.3R). The Consumer Duty applies to a firm's retail market business, and prospective customers count as retail customers (PRIN 2A.1). If an AI draft goes to a retail client, the Duty's standard applies. For commercial business clients, the Duty may not apply in the same way.
Client data. A controller "shall use only processors providing sufficient guarantees", and processing "shall be governed by a contract" (UK GDPR Article 28). If the tool processes client data on your behalf, the contract matters, not only the product.
Senior accountability. For senior managers, "You must take reasonable steps to ensure that any delegation of your responsibilities is to an appropriate person and that you oversee the discharge of the delegated responsibility effectively" (COCON 2.2.3R). This applies to the senior manager of an authorised firm. Appointed representatives sit under a different chapter (SUP 10A), which applies to the principal firm.
Senior accountability needs the most care, so here is what the sources actually say. The senior managers regime applies to firms in the SM&CR. An appointed representative is covered by a different part of the handbook, and the regime for appointed representatives sits in SUP 10A. If you are an appointed representative, the question is not "which senior manager signs this off?". It is "what does your principal require of you?", and that is a question for your principal and your practitioner, not for this article.
I have not written a rule here that I could not read in the handbook. Where I could not confirm the wording, I left it out. Suitability is one of those: the mortgage suitability rule I first pointed to is shown as deleted in the handbook.
So the honest answer to "who signs it off?" is that it depends on what kind of firm you are, and the handbook tells you which rule applies to which kind. Read the rule first. Then decide who signs.