Is this investment advice?

No. Serra Education provides process and tooling consulting only, never Serra Wealth investment advice. What you get here is a process-and-governance guide, not legal, investment, or compliance advice. Use it to structure your own decisions, and confirm every obligation against the primary source and your own counsel.

The blocker isn't the model — what is it?

It is the audit trail. Most wealth firms have already tried AI somewhere. Far fewer can show a reviewer where the data went, who checked the output, and how the decision would be reconstructed if a regulator asked. The binding constraint sits in the workflow around the model, not in the model you pick.

Do these obligations change if I switch AI tools?

No. None of the rules regulate which model you use. They regulate whether a human owns the output, whether client data stays contained, whether client-facing AI is disclosed, and whether you can reconstruct what the model did. A firm can swap one model for another and change nothing about its compliance position.

Where do the finder briefings come from?

Primary law, read by a person. Each obligation is sourced to the actual article, MiFID II, the GDPR, the EU AI Act, the FCA Handbook, ICO guidance, not to a scraped summary. Every line carries a citation and a confidence badge, and a person reviews each briefing before it is published.

How does the paid path work, and what does it cost?

It is three steps, in order, and the paid step is never first. Start with a free one-page report for your firm. Then a free 15-minute intro call. If it is useful, a 60-minute optimisation session is 250 EUR, and that fee credits in full toward a Tier 1 audit, which runs 2,000 to 10,000 EUR depending on firm size and the number of workflows in play.

Can I put live client data into an AI tool to test this?

Do not. Keep live client data out of any general-purpose AI tool. The report on this page is produced from a prompt you run inside your own environment, no client data leaves you, and Serra never asks you to send client data. Any real-data workflow needs a contracted tool, a lawful basis, and a data-protection impact assessment first.

Is Serra vendor-neutral?

Yes. Serra Education does not resell an AI stack, so the recommendation is what works in your firm, not what pays a referral. The engagement is about the governance around the model, which is portable across whichever tools you already run.

AI compliance obligations for a wealth management firm in the EU

4 AI-adoption compliance obligations apply, each cited to primary law.

AI that touches advice or suitability must stay inside your conduct rules

Rule: MiFID II Art 24 & 25

What it requires: Where an AI tool contributes to a personal recommendation or a suitability assessment, the firm remains fully responsible for acting honestly, fairly and professionally in the client's best interests, and for the suitability of the outcome. AI does not shift the conduct obligation off the firm.

Do this: Map every AI tool that can touch an advice, suitability or client-communication workflow, and keep a human sign-off on any output that reaches a client. Treat the tool as a drafting aid inside your existing suitability process, not a replacement for it.

Source: Directive 2014/65/EU (MiFID II), Articles 24-25; ESMA Public Statement on the use of Artificial Intelligence in the provision of retail investment services, 30 May 2024 (ref ESMA35-335435667-5924).

Confidence: Sourced

Keep records of the services and transactions the AI helps produce

Rule: MiFID II Art 16(6)

What it requires: The firm must arrange for records to be kept of all services, activities and transactions sufficient to let the competent authority monitor compliance, including where an AI system drafted, screened or supported the work.

Do this: Log which AI tool was used, on what input, and who reviewed the output, alongside the underlying client record, so the record of the service is complete whether or not a model was in the loop.

Source: Directive 2014/65/EU (MiFID II), Article 16(6).

Confidence: Sourced

Record and retain relevant client communications

Rule: MiFID II Art 16(7)

What it requires: Records of telephone conversations and electronic communications relating to (at least) transactions and the reception, transmission and execution of orders must be kept, and retained for five years, extendable to seven by the competent authority.

Do this: Make sure any AI that summarises calls, drafts client emails or transcribes meetings writes into a retained store, not an ephemeral chat. The retention obligation attaches to the communication, not to the tool.

Source: Directive 2014/65/EU (MiFID II), Article 16(7); Commission Delegated Regulation (EU) 2017/565 Art 72.

Confidence: Sourced

Guard automated decisions and disclose AI to the client

Rule: GDPR Art 22 & AI Act Art 50

What it requires: A client has the right not to be subject to a decision based solely on automated processing that produces legal or similarly significant effects (GDPR Art 22). Separately, under the EU AI Act, natural persons must be informed when they are interacting with an AI system unless it is obvious (Art 50 transparency).

Do this: Keep a person in the loop on any client-affecting decision, and add a short AI-use disclosure to client-facing material where a model contributed, the same disclosure Serra puts on its own briefings.

Source: Regulation (EU) 2016/679 (GDPR), Article 22; Regulation (EU) 2024/1689 (AI Act), Article 50.

Confidence: Sourced