Goodreturns highlights the article by Simon Papa, formerly of the FMA, now of Cygnus Law, pointing out that the current draft of the robo-advice exemption favours larger businesses. That was the angle reflected in the headline on Goodreturns. But later in the article there was a view which I would prefer to highlight. That robo-advice may end up being provided almost exclusively by large, overseas, companies, not the current market participants. Robo-advice probably rarely cannibalises full-personalised advice provided by a human professional. Robo-advice struggles to beat humans head-to-head. The natural target of robo-advice is the no-advice price comparison website for insurance, which it can beat easily in terms of confidence and outcomes, when well-designed. Yet the draft exemption, effectively prevents that kind of service. That's not to say that it couldn't be licensed: conceivably it could seek an individual exemption. But the worry is that the exemption represents the wider approach the FMA might take.