The new workforce risk financial services leaders are watching

Halfway through the year, the conversation among learning leaders in regulated finance has narrowed to one question. How does a firm build workforce capability, and prove it, while AI changes the work faster than most role frameworks can keep up? LinkedIn’s 2025 Workplace Learning Report found that nearly half of learning and talent leaders see a skills crisis. Fosway’s recent research puts AI and skills at the top of the strategic list. The pressure is not abstract. It shows up in specific programs that have to be redesigned and then defended.

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1. Regulators have moved the goalposts to competence

The clearest signal is coming from supervisors, and it is aimed at how firms evidence that their people are capable, not just trained. The Financial Conduct Authority’s (FCA) updated Conduct Rules guidance now states that role-relevant, scenario-based learning matters more than a one-off annual module, and that firms should assess whether it worked. Digital Operational Resilience Act(DORA) is in application across EU financial entities, raising the bar on operational resilience and on the competence of the people who manage technology and third-party risk. The European Central Bank(ECB) has asked euro area banks to submit plans for AI-enabled cyber threats. Consumer Duty adds a further layer, with the FCA continuing to publish on it through 2026 and expecting firms to show that staff decisions produce good customer outcomes.

Each of these turns a broad topic into a specific obligation: show that the person handling client exposure or a resilience control actually understands it, and that the understanding was assessed rather than assumed. For L&D, that is a measurement and design problem before it is a content problem.

2. The entry-level pipeline is changing under them

The second live problem is early careers, though not in its familiar form. Firms are still hiring junior talent. The Financial Services Skills Commission reported that early-career intake grew in 2025, led by apprenticeships rather than graduate schemes. What has changed is the shape of the role. PwC’s analysis shows that junior positions in AI-exposed sectors increasingly demand skills that used to sit two levels up. A new analyst may be asked to interpret a credit assessment or a portfolio concentration report that an AI tool has largely produced. If the learning pathway still assumes years of gradual exposure, the firm is handing decision-adjacent work to people it has not yet equipped to question the output.

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3. Managers are absorbing the change without support

Between the regulator and the graduate sits the line manager, and this is where most capability plans quietly fail. Deloitte found that among workers facing significant AI-driven change, 69% report a heavier workload and 43% name lack of time as their main barrier to adapting. LinkedIn reports that only 15% of employees say a manager helped them build a career plan in the last six months, down on the year before. Managers are being asked to coach teams through new tools and turn policy into daily behavior, usually with no relief on their own targets. That creates a dangerous gap. The people responsible for embedding conduct and judgment on the ground have the least capacity to do it, and learning built for them often assumes time and attention they no longer have.

4. What holds its value when AI access is universal

The line running through these problems is that access to AI no longer sets a firm apart. The Financial Services Skills Commission’s 2026 work makes the point plainly: the technology is available to everyone. What stays scarce is the domain knowledge to interrogate what a model produces and the judgment to own the consequence when it is wrong. A model can summarize a credit file or flag an anomaly in a cyber log. It cannot be accountable for a lending decision or a conduct breach. That accountability belongs to a named person, and it rests on whether they understand how risk moves across a portfolio and where a single decision creates exposure elsewhere in the firm.

This is the practical brief for the second half of the year. The learning that will matter maps to specific roles and the risks they carry, so a supervisor asking how competence was assessed gets a real answer. It is built for managers as they actually work rather than as an org chart imagines them. And it ramps entry-level capability fast enough to match the responsibility the work now puts on new hires.

It is also where deep, current domain knowledge earns its place over generic content. Learning written by people who understand the domain and tied to what a role is accountable for is what lets a firm say its workforce is capable and then show the working. That is the question finance L&D leaders are now being asked to answer, and it is a better use of the next two quarters than another wave of broad AI commentary.

That is the question finance L&D leaders are now being asked to answer, and it is a better use of the next two quarters than another wave of broad AI commentary.

Frequently Asked Questions

What workforce risk are financial services learning leaders watching?

Financial services learning leaders are focused on whether firms can build and prove workforce capability while AI changes roles faster than existing frameworks can adapt. The risk appears when employees take on decision-adjacent work without enough domain knowledge, judgment, or assessed competence, leaving firms unable to show that people understand the risks and responsibilities attached to their roles.

How have regulators changed expectations for workforce competence?

Regulators are placing greater emphasis on demonstrated competence rather than completion of one-off training. The FCA highlights role-relevant, scenario-based learning and assessment, while DORA, Consumer Duty, and supervisory attention to AI-enabled cyber threats increase expectations around resilience, customer outcomes, and accountability. Firms must show that employees understand relevant risks and that learning effectiveness was assessed rather than assumed.

Why must early-career learning pathways change as AI reshapes junior roles?

Junior employees are increasingly expected to interpret work that AI tools have already processed, such as credit assessments or portfolio concentration reports. This can bring responsibilities forward before traditional development pathways have prepared them. Learning programs therefore need to build domain knowledge and critical judgment earlier, so new hires can question AI-generated outputs instead of accepting them without understanding the wider risk implications.

Why are line managers a weak point in capability plans?

Managers are expected to coach teams through new tools, translate policy into daily behavior, and support career development while managing heavier workloads and unchanged targets. The article notes that time is a major barrier to adaptation and that few employees report receiving recent career planning support from a manager. Capability plans can fail when learning assumes managers have time and attention that they do not have.

What capabilities retain their value when AI access is universal?

When AI tools are widely available, domain knowledge and accountable judgment remain scarce and valuable. Employees need to understand how risk moves across a portfolio, identify where an output may be incomplete or wrong, and own the consequences of decisions. AI can summarize information or flag anomalies, but it cannot be accountable for a lending decision, customer outcome, resilience failure, or conduct breach.

What should finance L&D leaders prioritize in the second half of the year?

Finance L&D leaders should prioritize learning that maps to specific roles and the risks those roles carry. Programs should assess competence in a way that can be evidenced to supervisors, support managers within the realities of their workload, and accelerate entry-level capability to match changing responsibilities. Deep, current domain knowledge should guide the content so firms can explain how workforce capability was built and verified.

Intuition Know-How gives your teams that grounding. It is the digital learning solution for financial services trusted by the world’s largest banks and regulators, with expert-written coverage across banking, risk, and regulation that maps to what each role actually does.

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