The first quarter of 2026 has settled three questions that consumed most of 2025. A short briefing on what those settlements mean operationally.
1. BNPL formally inside the perimeter
The 2026 perimeter change brought BNPL into the consumer-credit regime in earnest. The bureau visibility on BNPL balances has thickened thin-file populations overnight, which means application scorecards calibrated against the old data signal are now stale across the cohort. Affordability methodologies that did not previously incorporate BNPL commitments are likewise stale. Quietly, the FCA is also reading BNPL customer comms against the same fair-value and vulnerable-customer standards as installment credit. Card issuers and instalment lenders inherit the operational consequences.
2. SWES 2 is operational, not narrative
The Second System-Wide Exploratory Scenario raised the bar for private credit firms more than the consultation papers suggested. Counterparty-level granularity, funding-and-redemption interaction, reverse-stress narrative — the Bank now wants demonstration, not assertion. Two weeks before the data call is too late to discover that the senior-vs-mezzanine identification or sponsor look-through your portfolio manager carries in their head was never in the data warehouse.
3. AI in claims separates shipped from demoed
Computer-vision damage assessment, AI triage at first-notice-of-loss and parametric instant payout on narrow product wedges are in production at the leaders. End-to-end agentic settlement of contested or complex claims, LLM-drafted decision letters without human review, and bodily-injury triage on AI signal alone are not. The leaders share a structure — bounded decisions, confidence thresholds, continuous monitoring on accuracy and complaints, a documented model-risk treatment the FCA could inspect on a Wednesday afternoon. The unshipped use cases have impressive accuracy metrics and no governance scaffolding.
What we are working on
This quarter the team has shipped: IFRS 9 macro-overlay recalibrations against the Renters' Rights Act vintage shift; a SWES 2 readiness practice for non-bank lenders; and a model-risk perimeter map for two retail-bank AI estates. Each is the kind of work we built Wersel Labs to do.
If any of those threads matter to your function next quarter, write to us — we read every reply.