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Layered AI™ for regulated decisioning

The DPC Decision-Evidence Checklist

BNPL / Deferred Payment Credit became a regulated activity on 15 July 2026 (FCA PS26/1). The question is no longer whether your decisions were right — it’s whether you can prove how they were made.

10
Questions
2 min
To complete
Instant
Score
Progress 0 of 10
A
Decision record — can you reconstruct any single decision?
1
For any affordability decision made last week, can you produce the full case record — data used, rules applied, outcome rationale — within one hour?If it takes an engineer and a day of log-diving, answer No.
2
Does the record show which version of your lending policy and decision rules was in force at the time of the decision?
3
Are declines and limit reductions evidenced to the same standard as approvals?Complaints and FOS referrals concentrate on adverse outcomes.
B
Data lineage — do you know what the decision saw?
4
Can you show which bureau data, open banking data and account history fed each individual decision (not just which sources you use in general)?
5
Where a third party supplied an input, can you evidence what they returned at decision time?Vendor logs age out; your obligation doesn’t.
C
Explainability — can a human defend the outcome?
6
Could a non-technical colleague explain to a customer, in plain language, why their application was approved or declined, using only the case record?
7
Where models or automated rules are involved, is there a documented, board-approved account of how they influence decisions?SM&CR: a named individual owns this answer.
D
Readiness — when someone asks
8
If the FCA requested a sample of 50 decision case files, could you deliver them within 5 working days without manual reconstruction?
9
Do complaints and FOS responses draw on the original decision evidence, rather than a fresh after-the-fact rationalisation?
10
Is decision evidence retained for the full regulatory retention period in a form that will still be readable after system changes?Re-platforming is where evidence quietly dies.
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