The user stays in their assistant. The broker controls the gates.
The surface changes. The broker's regulatory responsibility does not.ACBP defines what happens when a credit journey starts inside an AI assistant rather than on a broker's own website or app. The surface changes. The broker's regulatory responsibility does not.
What changes
Today, when a user applies for credit, the broker owns the surface. The user visits the broker's app, the broker's UI handles every interaction, and every step of the journey happens inside the broker's own system.
Today
The broker owns the surface
The user visits the broker's app or website. The broker controls the entire interaction.
Consent is captured on-page
The broker's UI handles all disclosures and explicit consent moments.
The audit trail is first-party
Every step happens inside the broker's system. Evidence is complete.
With ACBP
The AI owns the surface
The user stays in their assistant. The broker no longer controls the first interaction.
Consent must be explicit and captured
The broker issues blocking consent actions. The AI must resolve them — not infer agreement from conversation.
The audit trail is shared and structured
The broker receives structured events from the AI and maintains a complete, replayable case record.
The journey, step by step
Every AI-mediated credit journey follows the same path. Steps 2 and 4 are compliance gates — explicit, blocking, and logged. The AI cannot bypass or infer their resolution.
User provides intent
The AI gathers the user's goals, financial situation, and context through natural conversation.
A blocking gate is a compliance-critical step in the journey that the AI cannot bypass, infer from conversation, or skip. The broker issues a typed action — Disclosure, Consent, Declaration, Instruction. The case does not advance until the gate is explicitly resolved and logged.
How the audit trail works for every gate →Who does what
Three clearly defined roles, no overlaps.
User Agent (AI)
Mediates the interaction. Gathers information from the user. Presents offers and disclosures. Executes the broker's instructions faithfully. Does not give financial advice. Is not a regulated entity.
Credit Broker
Owns the regulated journey. Defines rules, flags, and decision points. Controls compliance gates. Maintains the audit trail. Accepts regulatory responsibility for the journey.
Lender
Makes the credit decision. Relies on broker accountability. Gets a new distribution channel — and a full, structured audit trail for every AI-originated application. The lender's relationship with the broker is unchanged.
Where AI meets credit today
ACBP is designed to work across every way a user might encounter agentic credit broking — from a white-labelled assistant embedded in a partner's product, to an autonomous agent acting on a standing mandate when the user isn't even there.
A partner embeds a ClearScore-provided AI assistant into their own product. ClearScore controls both the assistant and the compliance layer. No AI build required from the partner.
Audit trail: First-party. ClearScore controls the surface. Highest trust level. The simplest compliance path for partners without deep AI capability.
These are the five scenarios the protocol addresses, arranged from least to most disruptive.
Any market, same protocol
The protocol is jurisdiction-neutral. It does not encode any particular regulatory regime. Instead, it enforces roles, responsibilities, and communication — the things that must happen regardless of which rules apply. The broker remains responsible for understanding and complying with regulation in their market. The protocol governs the handshake, not the rulebook.
The result: a broker can implement ACBP in any market. A conforming AI assistant can operate across markets without needing to understand any individual regulatory framework.
Want to go deeper?
View ACB ProtocolRead the full specification, review the operations, and explore the technical detail. Follow the protocol's development.
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