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ai policy

AI Policy

Last updated 5/11/2026

This Artificial Intelligence Policy (“AI Policy”) sets out Earnly’s approach to the development, deployment, and use of artificial intelligence (“AI”) in connection with its platform (https://app.earnly.co.uk) and associated services (the “Services”).

This AI Policy is intended to provide transparency regarding how Earnly uses AI, including:

  • compliance with applicable UK laws and regulatory expectations;

  • responsible and ethical use of AI;

  • data sourcing and processing practices;

  • technical and organisational safeguards;

  • transparency to users; and

  • risk management.

This AI Policy reflects Earnly’s current practices and may be updated from time to time to reflect changes in technology, regulation, or industry standards.

This AI Policy should be read alongside Earnly’s:

  • Privacy Policy

  • Terms of Service

  • Acceptable Use Policy

1. Nature and Role of AI within Earnly

Earnly uses AI and automated processing to support the delivery of its Services, including:

  • categorising financial transactions;

  • identifying patterns in financial behaviour;

  • generating tax estimates and projections;

  • providing alerts, prompts, and recommendations; and

  • improving platform performance and user experience.

AI within Earnly is designed to support decision-making, not replace professional judgment.

All AI-generated outputs are informational only and must not be relied upon as financial, tax, or legal advice.

2. Compliance with UK Law and Regulatory Expectations

Earnly is committed to ensuring that its use of AI aligns with applicable UK laws and regulatory guidance, including:

  • the UK General Data Protection Regulation (UK GDPR);

  • the Data Protection Act 2018;

  • guidance issued by the Information Commissioner's Office; and

  • emerging UK frameworks relating to the responsible use of AI.

Earnly monitors regulatory developments and adapts its practices where appropriate.

3. Responsible and Ethical Use of AI

Earnly is committed to the responsible and ethical use of AI. In particular:

  • AI is not used to make legally binding decisions on behalf of users;

  • AI is not used to assess or determine eligibility for credit, employment, or other regulated outcomes;

  • AI outputs are not designed to replace professional advice;

  • AI is not used to intentionally mislead, manipulate, or exploit users; and

  • AI is used in a way that seeks to minimise bias, unfairness, or unintended harm.

4. Data Sources and Use of Data

AI systems used by Earnly may rely on:

  • financial data provided by users;

  • data obtained via Open Banking providers (with user consent);

  • system-generated or derived data (e.g. categorisation and behavioural insights); and

  • anonymised or aggregated usage data.

Earnly takes reasonable steps to:

  • ensure it has appropriate rights to use data processed within its systems;

  • limit the use of data to defined purposes;

  • prevent misuse of personal data; and

  • ensure compliance with data protection obligations.

Earnly does not knowingly use unlawfully obtained data or sensitive personal data outside the scope of its Services.

5. Technical and Organisational Measures

Earnly implements and maintains appropriate technical and organisational measures in relation to the development and use of AI, including:

  • internal policies governing the use and development of AI systems;

  • data protection and security controls (including encryption and access restrictions);

  • testing and monitoring of AI systems to assess performance, accuracy, and reliability;

  • controls to manage changes to AI models and systems; and

  • processes to identify and mitigate risks associated with AI use.

Despite these measures, AI systems may produce outputs that are incomplete, inaccurate, or unsuitable in certain circumstances.

6. Transparency

Earnly aims to ensure transparency in how AI is used within the Services.

Where appropriate, Earnly will:

  • inform users that AI is being used to generate outputs;

  • provide clear explanations of the purpose of AI-generated features; and

  • highlight the limitations of AI outputs.

Users should assume that certain features, including insights, categorisation, and tax estimates, may involve automated processing.

7. Limitations of AI

Users acknowledge and accept that:

  • AI outputs are based on available data and predefined logic;

  • outputs may not reflect individual circumstances or all relevant factors;

  • AI-generated insights may change as new data becomes available; and

  • outputs may contain errors, omissions, or inaccuracies.

AI outputs must not be used as the sole basis for:

  • filing tax returns;

  • making financial decisions;

  • determining legal or regulatory obligations.

Independent verification and, where appropriate, professional advice should be sought.

8. User Responsibility

Users remain solely responsible for:

  • reviewing and validating AI-generated outputs;

  • ensuring the accuracy of data provided to the platform;

  • complying with legal and tax obligations; and

  • making decisions based on appropriate independent judgment.

Use of Earnly does not transfer responsibility for financial or tax outcomes to Earnly.

9. Risk Management

Earnly adopts a risk-based approach to AI, including:

  • identifying potential risks associated with AI use;

  • assessing the likelihood and impact of such risks;

  • implementing controls to mitigate those risks; and

  • reviewing and updating controls as needed.

Earnly does not classify its AI systems as high-risk under current UK regulatory frameworks but continues to monitor developments.

10. No Reliance and Limitation of Liability

To the fullest extent permitted by law:

  • Earnly accepts no liability for decisions made based on AI-generated outputs;

  • Earnly does not guarantee the accuracy, completeness, or reliability of AI outputs; and

  • AI outputs are provided “as is” and for informational purposes only.

This AI Policy does not override or limit any provisions contained in Earnly’s Terms of Service, including those relating to limitation of liability.

11. Updates to this Policy

Earnly may update this AI Policy from time to time to reflect:

  • changes in technology;

  • regulatory developments; or

  • updates to industry best practices.

Updated versions will be published on Earnly’s website.

12. Contact

If you have any questions about this AI Policy:

Email: support@earnly.co.uk

Company: Earnly Ltd