AI regulation tracker · Topic hub

AI governance in banking: what regulators require, pillar by pillar.

Last updated Oct 5, 2026 · 41 authorities · every row linked to its document

AI governance in a bank is not one rule but six obligations assembled from different places: the board owns an inventory of what is running; predictive models are validated under model-risk guidance while generative and agentic AI are governed through broader enterprise risk; the data behind every model is owned, traceable and complete; bought models and cloud providers sit under third-party risk management; a person can explain and override any decision that touches a customer's credit; and voluntary frameworks from NIST and Treasury fill the gaps the rules leave. Each pillar below states the expectation in a few sentences and maps it to the documents that ask for it, across the 41 authorities this tracker follows.

Two of the pillars have their own pages: model risk management (the framework, model inventory, validation and the three lines of defense) and, for the customer-facing side of human oversight, AI chatbots in banking.

Who has to own AI in a bank?

Every supervisor that has spoken puts AI under the board and senior management, through the same governance architecture that already covers models and technology: named accountability, an inventory of what is running, policies for how it is approved, and effective challenge from risk, compliance and internal audit. US model-risk guidance revised in April 2026 keeps that structure for predictive models and leaves generative and agentic AI to broader enterprise governance; the UK's SS1/23 names a senior manager; the ECB's supervisors have said accountability for AI decisions must be clear and oversight must match AI's strategic weight.

RuleAuthorityWhat it requiresApplies
SR 26-2 / OCC Bulletin 2026-13 / FDIC FIL-15-2026Federal ReserveBoard and senior-management governance, a model inventory and independent validation for models in scope; generative and agentic AI are outside scope and left to broader risk-management and governance practices.In force from Apr 17, 2026
PRA SS1/23UK (BoE / PRA / FCA)Five model-risk principles for all models informing business decisions regardless of technology, AI-relevant tiering factors (unstructured data, explainability, bias), and a named Senior Management Function holder accountable for the framework.In force from May 17, 2024
ECB: 'Technology is neutral, governance is not'ECBClear accountability for AI decisions, senior-management oversight matching AI's strategic importance, and effective challenge from risk, compliance and internal audit.Stated Feb 24, 2026
FSB sound practices 1–4 (consultation)FSBStrategic direction and oversight, governance and accountability, AI inside the risk-management framework, organisational adaptability.Final report expected Oct 2026
NCUA Letter 26-CU-01NCUACredit-union supervisory expectations for AI governance, risk assessment and vendor oversight.In force

Which AI systems count as models, and what validation do they need?

In the US, a machine-learning system that processes input data into quantitative estimates is a model and needs documented development, independent validation, ongoing monitoring and outcomes analysis scaled to its materiality. The 2026 revision narrowed the definition so that simple arithmetic and deterministic rules fall out, and it explicitly excludes generative and agentic AI from model risk management while promising an interagency request for information. Outside the US the perimeter is wider: the PRA keeps AI and machine learning inside model risk management, and the ECB's internal-models guide tests machine-learning capital models for explainability and justified complexity.

RuleAuthorityWhat it requiresApplies
SR 26-2 (Fed)Federal ReserveRisk-based, materiality-driven validation and monitoring; 'complex quantitative method' definition; generative and agentic AI out of scope.In force from Apr 17, 2026
SR 11-7 (the 2011 framework)Federal ReserveThe validation disciplines that carry over: conceptual soundness, ongoing monitoring, outcomes analysis, effective challenge.Superseded Apr 17, 2026
ECB Guide to internal models, ML sectionECBMachine-learning capital models must be adequately explainable and their complexity justified by performance.In force from Jul 28, 2025
EBA follow-up report on ML for IRB modelsEBAPrinciple-based recommendations on understanding, documentation, validation and stability of machine-learning capital models.Published Aug 4, 2023
OCC Bulletin 2023-17 / SR 23-4 (third-party models)Federal ReserveVendor models are the bank's to understand and validate, with due diligence and monitoring through the relationship's life.In force

What do regulators expect of the data behind AI models?

Owned, traceable, complete and current: the BCBS 239 vocabulary that examiners use for risk data applies to training sets, feature stores and retrieval corpora, and the Basel Committee's January 2026 newsletter said AI makes robust data management more important, not less. The EU AI Act turns data governance into a legal duty for high-risk systems such as consumer credit scoring, with provenance, preparation, bias examination and gap analysis to be documented, from December 2, 2027 after the Digital Omnibus deferral.

RuleAuthorityWhat it requiresApplies
BCBS 239Basel CommitteeFourteen principles for risk-data governance, aggregation and reporting: ownership, architecture, accuracy and lineage, completeness, timeliness, adaptability.G-SIBs from 2016
BCBS 239 implementation newsletterBasel CommitteeAI and advanced automation depend on high-quality data; lineage and ad hoc reporting still 'a work in progress'.Published Jan 6, 2026
EU AI Act, Article 10EU AI ActDocumented data governance for training, validation and testing data of high-risk systems, including credit scoring of natural persons.Stand-alone Annex III systems from Dec 2, 2027
Treasury AI cybersecurity reportU.S. TreasuryIdentified a 'fraud data divide' and proposed data 'nutrition labels' for vendor AI; became the AIEOG workplan.Published Mar 27, 2024

How is a bank's reliance on external AI models and cloud providers supervised?

Through third-party risk management rather than a separate AI rule. The 2023 US interagency guidance covers the full lifecycle from due diligence to termination and expects validation of purchased models; the Basel Committee's December 2025 principles reach nth-party supply chains and concentration; and the FSB has singled out generative AI's dependence on a small number of hardware, cloud and model suppliers as a financial-stability vulnerability to monitor.

RuleAuthorityWhat it requiresApplies
SR 23-4 / OCC 2023-17 / FDIC FIL-29-2023Federal ReservePlanning, due diligence, contracting, ongoing monitoring and termination for every third-party relationship, including AI tools and foundation-model access.In force from Jun 7, 2023
BCBS Third-Party Risk PrinciplesBasel CommitteeTwelve principles covering board accountability, due diligence, contracts, monitoring, continuity and exit, including nth-party chains and concentration.Published Dec 10, 2025
FSB AI monitoring reportFSBThird-party dependencies and provider concentration named as vulnerabilities for authorities to track.Published Oct 10, 2025
FSB third-party risk toolkitFSBToolkit for managing third-party and outsourcing risk, including critical service providers.Published Dec 4, 2023

When must a person be able to explain or override an AI decision?

Whenever the decision touches a consumer's credit: US adverse-action law requires the specific principal reasons for a denial regardless of how complex the model is, the EU AI Act requires human oversight and a fundamental-rights impact assessment for high-risk credit scoring, and Colorado's Automated Decision-Making Technology Act adds notice, a plain-language explanation after an adverse outcome and human review from January 1, 2027, with a lender's ECOA notice satisfying the disclosure duty for the same decision.

RuleAuthorityWhat it requiresApplies
ECOA / Regulation B adverse actionCFPBSpecific principal reasons for adverse credit action; model opacity is not a defence.In force
FCRA adverse action and key factorsCFPBKey factors that adversely affected a credit score must be disclosed.In force
EU AI Act, Articles 14 and 26–27EU AI ActHuman oversight, deployer duties and a fundamental-rights impact assessment for high-risk credit scoring.Stand-alone Annex III systems from Dec 2, 2027
Colorado SB 26-189 (ADMT Act)Colorado AI ActConsumer notice, a plain-language explanation within 30 days of an adverse outcome, data access and correction, human review.Effective Jan 1, 2027
CPPA ADMT regulations (California)California CPPANotice, opt-out and access rights for automated decision-making technology in significant decisions, plus risk assessments.In force

What do banks use to govern generative and agentic AI where the rules stop?

The NIST AI Risk Management Framework and its generative-AI profile, Treasury's financial-services adaptation of it, and, for cyber, the New York and ECB letters on AI-enabled threats. None is binding on banks, but together they are what most US institutions cite for the systems that model-risk guidance now leaves out, and what examiners ask about when a bank's AI policy is on the table.

RuleAuthorityWhat it requiresApplies
NIST AI RMF 1.0NISTGovern, Map, Measure, Manage and seven trustworthiness characteristics.Voluntary
NIST AI 600-1 (Generative AI Profile)NISTTwelve generative-AI risks and more than 200 suggested actions mapped to the framework.Voluntary
Treasury FS AI RMF and AI LexiconU.S. TreasuryThe NIST framework adapted to financial services' operational, regulatory and consumer-protection specifics, with a shared vocabulary.Published Feb 19, 2026, non-binding
DFS AI cybersecurity letterNY DFSAI-enabled social engineering, AI-enhanced attacks, data exposure and vendor dependency mapped to 23 NYCRR Part 500 obligations.In force
ECB 'Dear CEO' letter SSM-2026-0301ECBEvery significant institution to assess AI-enabled cyber threats and submit an action plan to its supervisory team.Plans due Oct 31, 2026

How do large banks practise responsible AI while innovating?

The largest US banks govern AI mostly through the structures they already run for model, technology and operational risk, and say so in their filings: Goldman Sachs has a Firmwide Artificial Intelligence Risk and Controls Committee reporting to its technology risk committee; Citigroup's board Technology Committee reviews management's approach to generative AI; Truist bases its AI program on the NIST AI Risk Management Framework with board oversight; BNY folds model risk management into a cross-functional AI risk framework. A few have published principles (PNC's six Responsible AI Principles, run by a working group under model risk management) or testing tools (JPMorgan Chase's Fence guardrails for hallucination, topic drift and prompt injection). The rest disclose AI mainly as a risk factor, and none has published a separate responsible-AI policy in its 10-K.

BankWhat it has disclosed about governing AIWhere
Goldman SachsA Firmwide Artificial Intelligence Risk and Controls Committee oversees the risks of using AI and reports to the Firmwide Technology Risk Committee.2025 Form 10-K (Feb 2026)
CitigroupThe board's Technology Committee oversees and reviews management's approach to generative AI; Citi says it has policies governing emerging technologies, including in model risk management.2025 Form 10-K (Feb 2026)
TruistIts AI program is 'foundationally based' on the NIST AI Risk Management Framework Core, and oversight of the program is a regular focus of the board and its risk and technology committees.2025 Form 10-K (Feb 2026)
BNYModel risk management covers AI use cases, including large language models, and is integrated into a cross-functional AI risk management framework with an active model inventory.2025 annual report, Form 10-K Exhibit 13.1 (Feb 2026)
Bank of America'To address AI-related risks, we have implemented internal processes and governance frameworks', with compliance and operational-risk teams assessing them independently.2025 Form 10-K (Feb 2026)
PNCSix Responsible AI Principles (accountability; transparency, explainability and accuracy; inclusion; fairness; reliability and security; privacy) and a Responsible AI Working Group, managed by Model Risk Management, that reports to the Operational Risk Committee.PNC corporate-responsibility page (undated)
JPMorgan ChaseThe Fence guardrail framework tests each large-language-model use case for hallucination, topic drift and prompt injection using synthetic data.JPMorganChase technology blog (Apr 2026)
Capital OneNames the policies governing how data, models and AI are acquired, validated, stored and analysed as a dependency in its 10-K, and co-founded the USC–Capital One Center for Responsible AI and Decision Making in Finance (CREDIF) in April 2024.2025 Form 10-K; Capital One tech blog (Apr 2024)
Wells FargoDiscloses AI as a risk: data may be inaccurate or biased and some models have 'limited transparency'; 'even though we may have controls', AI could lead to poor decisions.2025 Form 10-K (Feb 2026)
American ExpressDiscloses the risk of failing to 'safely deploy AI systems and implement appropriate governance and controls'.2025 Form 10-K (Feb 2026)

SOURCES: Goldman Sachs 2025 Form 10-K ↗ · Citigroup 2025 Form 10-K ↗ · Truist 2025 Form 10-K ↗ · BNY 2025 annual report (Form 10-K Exhibit 13.1) ↗ · Bank of America 2025 Form 10-K ↗ · PNC, Protecting Customer Privacy and Security ↗ · JPMorganChase, Strengthening LLM guardrails with synthetic data generation ↗ · Capital One 2025 Form 10-K ↗ · Capital One and USC partner to drive responsible AI (CREDIF) ↗ · Wells Fargo 2025 Form 10-K ↗ · American Express 2025 Form 10-K ↗

Which governance documents has each authority published?

AuthorityGovernance documents in the tracker
Federal ReserveCook: Opportunities and Risks of AI (May 2026) Final · Bowman: AI in the Financial System (May 2026) Final · SR 26-2 In force · SR 23-4 In force · 2021 BSA/AML Model Risk Statement Superseded · 2021 Interagency AI RFI Final · SR 11-7 Superseded
OCCOCC Semiannual Risk Perspective, Spring 2026 Final · OCC Bulletin 2026-13 In force · Acting Comptroller Hood, 'AI in Financial Services' (Apr 2025) Final · OCC Bulletin 2023-17 In force · OCC Bulletin 2021-19 Superseded · 2021 Interagency AI RFI (OCC Bulletin 2021-17) Final · OCC Bulletin 2011-12 Superseded
FDICHill House oversight testimony (Jun 2026) Final · Hill 'Charting a New Course' speech Final · FDIC FIL-29-2023 In force · FDIC FIL-20-2021 Final
NCUAHauptman Senate testimony (Feb 2026) Final · NCUA Letter 26-CU-01 In force · NCUA AI Compliance Plan (2025) Final · NCUA Credit Union AI Resource Center In force · NCUA Board AI briefing (Jul 2025) Final · NCUA testimony to House AI Task Force (2022) Final · NCUA Letter 07-CU-13 In force
CFPBCFPB withdrawal of 67 guidance documents (May 2025) In force · CFPB comment to Treasury on AI in financial services (2024) Final · Joint Statement on Automated Systems (CFPB, DOJ, EEOC, FTC) Final
SECAtkins remarks at Investor Advisory Committee (Sep 2026) Final · Atkins remarks at FSOC AI roundtable (Mar 2026) Final · Investor Advisory Committee AI disclosure recommendation Final · Division of Examinations FY2026 Priorities In force · SEC withdrawal of proposed rules (33-11377) Final · SEC v. Saniger (Nate, Inc.) Final · Presto Automation AI-washing order Final · Division of Examinations FY2025 Priorities Superseded · Delphia / Global Predictions AI-washing settlements Final · Gensler 'AI washing' remarks at Yale (Feb 2024) Final · SEC Predictive Data Analytics proposal (34-97990) Withdrawn
CFTCCFTC Innovation Task Force In force · CFTC Staff Advisory 24-17 on AI In force · Johnson Statement on AI in Derivatives Markets (Dec 2024) Final · CFTC TAC Responsible AI Report Final · CFTC AI Request for Comment (2024) Final
FinCEN2026 AML/CFT Program Proposed Rule Proposed · 2024 AML/CFT Program Proposed Rule (withdrawn) Withdrawn · Anti-Money Laundering Act of 2020 In force · FinCEN Innovation Hours In force · 2018 Joint Statement on BSA/AML Innovation In force
U.S. TreasuryFSOC AI Innovation Series (Mar–May 2026) Final · Treasury FS AI RMF and AI Lexicon (Feb 2026) Final · FSOC 2025 Annual Report Final · Treasury AI in Financial Services report (Dec 2024) Final · FSOC 2024 Annual Report Superseded · Treasury AI RFI (June 2024) Final · Treasury AI cybersecurity risks report (Mar 2024) Final · FSOC 2023 Annual Report Superseded
White HouseEO 14365 In force · America's AI Action Plan In force · EO 14179 In force
FINRA2026 FINRA Annual Regulatory Oversight Report In force · FINRA Regulatory Notice 24-09 In force
NY DFSDFS Heightened Threat Environment Guidance (May 2026) In force · New York RAISE Act Final · Asrow Assembly Statement on AI in Insurance (Dec 2025) Final · Insurance Circular Letter No. 7 (2024) In force · DFS Virtual Currency Customer Service Guidance (May 2024) In force · DFS Proposed AI Insurance Circular Letter (Jan 2024) Superseded · 23 NYCRR Part 500 In force
NYC DCWPNYC Local Law 144 (AEDT) In force
Colorado AI ActColorado AG proposed ADMT rules Comment period open · HB 26-1263 Final · SB 26-189 Final · SB 25B-004 Superseded · SB 24-205 Superseded · Colorado SB 21-169 and Regulation 10-1-1 In force
California CPPASB 947 Final · AB 1609 Final · California SB 53 (Transparency in Frontier AI Act) In force · CPPA ADMT, risk-assessment and cybersecurity-audit regulations In force · Civil Rights Council ADS employment regulations In force · California AG legal advisory on AI (Jan 2025) Final · Cal. Civ. Code §1798.145 (CCPA exemptions, incl. GLBA data) In force
Texas AGTexas TRAIGA (HB 149) In force
Utah Division of Consumer ProtectionUtah SB 226 (2025) In force · Utah AI Policy Act (SB 149) In force
Illinois IDHRIllinois HB 3773 (P.A. 103-0804) In force · Illinois AI Video Interview Act (820 ILCS 42) In force
Massachusetts AGMassachusetts AG Earnest Operations settlement (July 2025) In force · Massachusetts AG AI Advisory (April 2024) In force
New Jersey DCRNJ DCR Algorithmic Discrimination Guidance (January 2025) In force
NISTAI RMF critical-infrastructure profile (concept note) Proposed · CAISI RFI on AI agent security (2026) Proposed · NIST IR 8596 (Cyber AI Profile) Proposed · NIST COSAiS control overlays Proposed · NIST AI RMF 1.0 In force · NIST AI RMF Playbook In force
EU AI ActRegulation (EU) 2026/1744 (Digital Omnibus on AI) In force · Commission guidelines on AI Act Article 50 transparency In force · Draft Commission guidelines on high-risk classification Proposed · EBA factsheet on the AI Act Final · Commission GPAI model guidelines In force · Commission guidelines on the AI system definition In force · Commission guidelines on prohibited AI practices In force · Regulation (EU) 2024/1689 In force · DORA (Regulation (EU) 2022/2554) In force
ECBECB 'Dear CEO' letter on AI-enabled cybersecurity threats (SSM-2026-0301) In force · Machado speech: 'Technology is neutral, governance is not' (Feb 2026) Final · Montagner speech: 'Encouraging innovation, managing risks' (Feb 2026) Final · Supervision Newsletter: AI use cases for credit scoring and fraud detection (Nov 2025) Final · SSM supervisory priorities 2026–28 In force · Machado speech: 'Artificial intelligence and supervision: innovation with caution' (Oct 2025) Final · ECB Guide on outsourcing cloud services In force · Supervision Newsletter: suptech infrastructure (May 2025) Final · ECB digitalisation sound practices report (July 2024) In force · Cipollone speech: 'Artificial intelligence: a central bank's view' (July 2024) Final · ECB FSR May 2024 AI special feature Final
EBAESA Statement on ICT risks from frontier AI models (JC 2026 25) In force · EBA factsheet: AI Act implications for the EU banking and payments sector Final · EBA Chair letter to the Commission on the AI Act mapping exercise (EBA/2025/D/5384) Final · EBA Work Programme 2026 In force · EBA report: Rising application of AI in EU banking and payments (Sep 2025) Final · EBA Guidelines on loan origination and monitoring (EBA/GL/2020/06) In force · EBA Report on Big Data and Advanced Analytics (EBA/REP/2020/01) Final
ESMAESMA AI statement ESMA35-335435667-5924 Final
EIOPAEIOPA Opinion on AI governance and risk management (EIOPA-BoS-25-360) In force
UK (BoE / PRA / FCA)Bailey: Frontier AI and the Question of Governance (Sep 2026) Final · FCA multi-firm review: Frontier AI and cyber resilience (Sep 2026) In force · HM Treasury Financial Services AI Adoption Plan (Jul 2026) Final · 2026 BoE/FCA AI survey Final · BoE/FCA/HMT joint statement on frontier AI and cyber resilience (May 2026) In force · BoE response to Treasury Committee AI inquiry (Apr 2026) Final · BoE/PRA plan for safe AI innovation (Apr 2026) Final · DSIT/DBT strategic letters to regulators (Jan 2026) Final · FCA FS25/5 Final · Data (Use and Access) Act 2025 In force · FPC Financial Stability in Focus: AI (Apr 2025) Final · 2024 BoE/FCA AI survey Final · FCA AI Update (Apr 2024) Final · UK AI white paper government response (CP 1019) In force · FS2/23 Final · PRA SS1/23 In force · ICO Guidance on AI and data protection In force · DP5/22 Final · 2022 BoE/FCA ML survey Superseded · FCA PS22/9 Consumer Duty In force
BaFinBaFin guidance on ICT risks in the use of AI Final · BaFin/Bundesbank ML in risk models results Final · BaFin BDAI principles paper Final
ACPRACPR discussion document on AI governance Final
DNB / AFMAFM and DNB report on the impact of AI Final · DNB SAFEST AI principles Final
FINMAFINMA Guidance 08/2024 Final
OSFIOSFI FIFAI II report (AGILE framework) Final · OSFI Guideline E-23 Final · OSFI-FCAC AI Risk Report (2024) Final · OSFI Guideline B-10 In force
MASMAS MindForge AI Risk Management Toolkit Final · MAS Consultation Paper P017-2025 (AI Risk Management Guidelines) Proposed · MAS AI Model Risk Management information paper Final · MAS FEAT Principles In force
HKMAHKMA GenA.I. Sandbox++ joint circular In force · HKMA GenA.I. Sandbox circular In force · HKMA circular on AI for monitoring of suspicious activities In force · HKMA GenAI consumer protection circular In force · HKMA BDAI consumer protection principles In force · HKMA High-level Principles on Artificial Intelligence In force
Hong Kong SFCSFC Circular 26EC32 (AI-enabled cyberattacks) In force
Japan FSAJapan FSA/BOJ frontier AI request In force · Japan FSA AI Discussion Paper v1.1 Final · Japan FSA AI Discussion Paper v1.0 Superseded
APRA / ASICAPRA AI Letter to Industry (April 2026) Final · ASIC REP 798 Final · APRA CPS 230 In force
RBIRBI draft Guidance on Regulatory Principles for Model Risk Management Proposed · RBI FREE-AI framework Final · RBI draft circular on Regulatory Principles for Management of Model Risks in Credit Proposed
FSBFSB Chair's letter to G20 (Aug 2026) Final · Responses to FSB AI sound practices consultation (Aug 2026) Final · Bowman remarks at FSB AI outreach (July 2026) Final · FSB AI sound practices consultation (June 2026) Proposed · FSB AI monitoring report (Oct 2025) Final · FSB next steps on AI monitoring (Oct 2025) Final · FSB AI financial stability report (Nov 2024) Final · FSB third-party risk toolkit (2023) Final · FSB 2017 AI/ML report Final
Basel CommitteeBCBS ICT Risk Management Report (June 2026) Final · BCBS 239 Implementation Newsletter (Jan 2026) Final · BCBS Third-Party Risk Principles (Dec 2025) In force · BCBS Work Programme 2025–26 In force · BCBS AI/ML Newsletter (March 2022) Final · BCBS Principles for Operational Resilience (2021) In force · BCBS 239 In force
IOSCOIOSCO FR/02/2026 In force · IOSCO FR06/2021 In force
DateEventDocument
Jul 24, 2026Digital Omnibus defers EU high-risk duties to Dec 2027Regulation (EU) 2026/1744 (Digital Omnibus on AI)
Jun 10, 2026FSB consults on twelve sound practicesFSB AI sound practices consultation (June 2026)
May 14, 2026Colorado re-enacts its AI law as the ADMT ActSB 26-189
Apr 17, 2026SR 26-2 replaces SR 11-7; generative and agentic AI carved outSR 26-2
Feb 19, 2026Treasury FS AI RMF and lexiconTreasury FS AI RMF and AI Lexicon (Feb 2026)
Dec 10, 2025Basel third-party risk principles reach AI supply chainsBCBS Third-Party Risk Principles (Dec 2025)
Jul 26, 2024NIST generative-AI profileNIST AI 600-1 (Generative AI Profile)
Jul 12, 2024EU AI Act published; credit scoring is high-riskRegulation (EU) 2024/1689
Jun 7, 2023SR 23-4 third-party guidance covers vendor AISR 23-4
May 17, 2023PRA SS1/23 keeps AI inside model risk managementPRA SS1/23
Jan 26, 2023NIST AI RMF 1.0 publishedNIST AI RMF 1.0
Jan 9, 2013BCBS 239 sets the data-governance standardBCBS 239
Apr 4, 2011SR 11-7 makes model governance an examinable disciplineSR 11-7

Which of the 120 largest US banks have disclosed AI governance arrangements?

93 of the 120 bank pages on this site record a governance-related AI activity, from AI committees and chief AI officers to training programmes and model-data controls. Each links to the bank's page, where the claim is sourced.

BankWhat the record showsStatus
JPMorganFirm-wide AI use-case portfolio: Almost 1,000 use cases, about 50 of them 'really important' across risk, fraud, marketing, hedging, prospecting, note-taking, idea generation and document reading; AI solutions in production doubled in 2025.In production
BofAThe Academy simulators: AI conversation simulators for employee coaching.In production
GoldmanTrade and transaction accounting agents: Automating accounting for trades and transactions.Pilot
Morgan StanleyCompliance task automation: Bots handling routine non-financial-risk work. LeadIQ: AI that introduces advisors to clients interested in advice and matches individuals with advisors.In production
U.S. BankAI Essentials Channel: Skills Academy training on using company-approved AI tools in daily work.In production
PNCModel-data nutrition labels: Adopting the FSSCC concept for documenting training and input data.Rolling out
TruistClient Pulse: Patent-pending AI aggregating client feedback across millions of conversations.Pilot
SchwabSchwab Advisor AI in Action: Education, peer networking and resources for RIAs adopting AI. Advisor Services AI tooling: AI to move data across advisers' systems, automate tasks and answer questions on Schwab policies and procedures.In production
BNYAnomaly detection in daily calculations: Flags areas for review in minutes instead of hours. Community-bank AI training: Free AI and cyber training for 1,000 community-bank executives, led by senior BNY leaders.In production
TDAgent observability and guardrails: US CIO describes chain-of-thought monitoring of agent reasoning plus guardrails and human oversight at design and operational stages, to contain agents that find unpredictable routes to a goal.In production
Fifth ThirdMerger-conversion monitoring: AI tools tracking the Comerica integration.In production
HuntingtonEnterprise-wide AI program: Five areas: software delivery, agentic process transformation, customer-facing use cases, colleague productivity and training, and data platforms.In production
BMOResponsible AI framework: Accountability, reliability, security, explainability, transparency, fairness, privacy, sustainability. Approved-tools rule and Microsoft Copilot: Only BMO-approved AI tools may be used for business; Copilot and Copilot Chat under acceptable-use guidance.In production
First CitizensResponsible-AI framework: A framework for responsible AI adoption and governance, established before the bank set out to scale AI use cases; benefits are tracked for every AI use case.In production
CitizensBusiness Pulse survey research on client AI adoption: Quarterly small-business survey tracking AI spending and adoption among Citizens' commercial clients.In production
AmexThird-generation data and analytics platform: Public-cloud platform for personalisation, servicing, fraud and GenAI and agentic use cases; 90% faster key marketing and fraud processes.Rolling out
M&TData lineage, Edison and the Data Academy: The data foundation under the AI program; ~2,000 employees trained.In production
AllyFour-layer AI governance: Working group, steering council, enterprise committee and board; mandatory training; Responsible AI Institute membership.In production
Northern TrustShared semantic data layer for AI agents (OSI): Open-source data definitions so agents across firms ground on the same meanings.Announced
PinnacleFirm AI policy: An ethics-and-effectiveness policy for AI deployment across the business. Generative-AI restriction in the code of conduct: Team members may not use gen-AI applications or put proprietary data into unauthorised applications without approval through internal governance channels.In production
UBSUBS Claves platform and AI risk committee: One platform with model routing and evaluation; AI Operating & Risk Committee under a group AI policy. RiskLab model development and validation (Domino): An auditable AI model-development platform built on Domino Data Lab, being rolled out across the bank.Rolling out
City NationalPost-remediation risk management: Controls rebuilt after the 2024 OCC order; the frame for any AI deployment at the bank.In production
FlagstarIntegrated AI governance workflow: Business case, compliance review and multi-level approvals in one auditable system. AI strategy committee and tiered model routing: The CIOO chairs an AI strategy committee attended by the CEO that prioritises a revenue and expense-reduction backlog; StarIQ routes work to three model tiers by complexity to manage cost.In production
WebsterCategory IV data and risk infrastructure: Data collection, storage and governance roles; regulatory-reporting capability.In production
First HorizonEnterprise Data Hub and data marketplace: Unified data with permission-based discovery of approved data products.Pilot
Old NationalAI for first-line risk management: The CEO's next target: 'checkers of checkers' work needed to embed risk into the first line as the bank grows.Announced
UMBPost-acquisition systems conversion: Product mapping, customer migration and platform consolidation after Heartland. Machine learning across the organisation: The CEO's description on the Q1 2026 call; no specific use cases, platform or figures disclosed.In production
SouthStateAI enablement programme: Office hours, AI Central hub, crowdsourced prompt library; adoption run as change management.In production
ColumbiaPost-merger systems conversion: Pacific Premier converted in Q1 2026 after the Umpqua integration.In production
CIBC'Agentic AI with humans in control': Human judgment, governance and culture at the centre of agent design.In production
ValleyFive-tier AI access and monthly spend tracking: Specialised tiers for engineering, QA and model risk; ~80 open-access power users. Valley Foundry: A dedicated capability to identify, test and advance emerging technologies — initially AI, cybersecurity, and data and analytics — through startup, fintech and vendor partnerships.In production, Announced
BOK FinancialData-first model for responsible AI scaling: Enterprise data treated as a shared asset under the chief data and analytics officer.Rolling out
FNBEthical and compliant AI strategy: Explicit remit of the director of AI and innovation.Rolling out
SoFiPlanner-evaluated Coach with human escalation: Financial planners evaluate Coach's answers; rule sets escalate out-of-scope conversations; actions require member authorisation.In production
EverBankOmnichannel and customer-platform transformation: Digital, voice, contact-centre and branch context sharing under the head of digital and customer platforms.Rolling out
Raymond JamesAI Academy for advisors and associates: A four-course programme; nearly 20,000 completions by July 2026. Chief AI officer and AI strategy office: Cross-business identification of analytics, ML and gen-AI opportunities.In production
AssociatedLine-of-business AI accountability and board oversight: Senior director of AI stewards risk and data; board technology committee.In production
ProsperityReal-time core platform: New processing system as the stated base for future innovation; no AI use disclosed.In production
Bank OZKNo disclosed internal AI use: Transcripts and releases contain no operational AI, automation or model references.Announced
Atlantic UnionExploratory AI programme: 'Exploring exciting opportunities with Artificial Intelligence'; agentic and third-party model risks flagged.Pilot
CommerceAI pillar in the enterprise data strategy: AI roadmap plus data-platform modernisation for speed to insight.Rolling out
Hancock WhitneyAI Working Group: Legal, compliance, risk and IT; approves AI use cases and reports to the IT Risk Governance Committee; board oversight of AI.In production
BankUnitedOpportunitiAI use-case programme: Per AWS's case study, an initiative rolled out to identify further generative-AI use cases and align business divisions. AI use 'not material' in filings: The 10-K calls current AI use 'not material to our operations'; no AI vendor or budget named in filings.Rolling out, Announced
United BankNo disclosed AI deployment: No AI programme, vendor or leader named in releases or investor materials.Announced
Texas CapitalAI enablement under the CDIO: Data platforms, AI enablement and security in one technology organisation.Rolling out
FultonCustomer education on AI tools: AI in investing (private bank) and AI budgeting apps (education centre).In production
GlacierNo disclosed AI deployment: Annual report and earnings materials describe no AI use; AI appears only as a risk factor.Announced
Eastern BankInnovation-through-experimentation culture: CDO-led programme; AI framed as a workplace efficiency tool.In production
Axos BankAI governance framework and enterprise AI assistant: Governance framework and infrastructure to educate, train and deploy AI tools to all team members; more than 500 on an enterprise AI assistant.In production
United CommunityCapacity-building through AI productivity: Clearing postponed product and process improvement projects.Announced
ArvestInnovation culture programme: Product and innovation office under Amy Morbeck; Fortune recognition.In production
WaFd BankBuild 2030 digital focus: Data used to anticipate client needs; NPS tracked as the outcome metric.In production
WesBancoBoard Technology Committee and AI expertise criterion: A board Technology Committee (chaired by Zahid Afzal) and AI listed among desired director expertise in the 2026 proxy.In production
RenasantSecurity review for AI-involving products and processes: New products, delivery methods or back-office processes, 'each of which may involve the incorporation of AI technologies', must be assessed for information-security implications; the board Technology Committee oversees IT strategy and receives the CISO's report.In production
First Interstate'One clean data source' consolidation: Data foundation for AI and other technology initiatives.Rolling out
Customers BankStandardised AI risk framework and AI Innovation Lab: Enterprise governance for scaled deployment. AI charter, acceptable-use policy and use-case scoring: Monthly executive AI charter meetings on compliance, risk and policy; uses scored on value, cost, time to develop and risk.In production
Rockland TrustOffice of Digital Innovation and AI governance framework: Gate for AI investments, favouring use cases with meaningful payback within a moderate risk approach; the governance model itself was still 'in process' in the September 2026 deck.Rolling out
Simmons BankEnterprise Data Office: Data governance, data literacy and data-driven decision-making established under the first CDO.In production
First HawaiianAI programme strategy and governance: Owned by the Digital Banking and Services Division under Jason Dang. Generative-AI usage policies: Written policies and technical safeguards for employees' and contractors' use of generative-AI tools; enterprise tools only for confidential inputs (merger-agreement representations).In production
Cathay BankNo disclosed AI deployment: Annual and responsibility reports silent on AI. Board oversight with AI expertise: Audit committee chair credited with insight into data analytics, automation and AI; a second director brings IT and information-security experience.Announced, In production
Bank of HawaiiResponsible-AI governance framework: Policies, oversight committees and ethical review protocols established in 2025. AI listed as an enterprise risk: Technology, AI and cybersecurity risk factors in the 10-K.In production
Centennial BankNo disclosed AI deployment: Earnings materials silent on AI.Announced
First Financial BankNo disclosed AI deployment: No AI reference in investor materials. AI strategy under construction; open AI sites blocked: The CISO's team is building the AI strategy by asking for each proposal the business case, the use case, who manages it and where the data goes, with organisational device access to open AI sites blocked meanwhile.Announced
Mechanics BankNo disclosed AI deployment: No named AI tool, vendor or budget; the Q1 2026 investor presentation says the technology roadmap is increasingly focused on AI tools for productivity. (Corrected 2026-09-24: previously said earnings materials were silent on AI.)Announced
Seacoast BankBoard technology and information-security expertise: March 2026 board refresh adds a sitting financial-services CIO whose remit includes AI, data and analytics.In production
Optum BankAgentic-AI lending perspective from the chief credit officer: Public commentary on AI in lending and cross-unit data sharing.Announced
Merchants Bank of IndianaNo disclosed AI deployment: Earnings materials silent on AI.Announced
Stifel BankAI thought leadership for clients: Research outlook on AI's economic effects.In production
TrustmarkPost-conversion efficiency programme: Management attention shifting to efficiency gains and possible M&A.Announced
Bank of HopeAcquisition integration (Territorial, SMBC MANUBANK): Hawaii and Japanese-corporate banking added to the Korean-American core.Rolling out
ServisFirst BankAI in the technology-change risk factor: 10-K: rivals with greater resources may out-invest the bank in technology, including AI-driven products.In production
Busey BankEnterprise AI and data-science function: Strategy, communication and execution of responsible AI/ML models across business units.Rolling out
Community Bank N.A.Dedicated AI team: More than a dozen staff, a handful fully dedicated; efficiency focus. Enterprise automation programme: More than 200,000 hours saved over three years, which management says helped keep headcount roughly flat while the business grew.In production
Enterprise Bank & TrustClient AI education (Enterprise University): AI strategy and Copilot courses for business owners. Fall 2026 Enterprise University: evaluating AI tools: More than 30 no-cost courses, with trending topics including evaluating AI tools and aligning AI adoption with business strategy.In production
FirstBankNo disclosed AI deployment: Earnings materials mention AI only in the forward-looking-statement risk list; the 10-K discloses limited, non-critical internal use (see below).Announced
First United BankTechnology as enterprise capability: Strategy, operating model, data, risk and digital experience connected under one programme. AI program strategy and execution function: A named SVP-level director of AI program strategy and execution and an analytics team; no AI use case, model or vendor disclosed.In production, Announced
Banner BankGenerative AI policy and Fintech Council vetting: Board-approved policy since 2023; every proposed Gen AI application is vetted by the Fintech Council against strategic priorities, values, risk appetite and data-security policies.In production
SynchronyResponsible AI Working Group and generative-AI risk oversight: A working group anchors responsible use; risks related to generative AI are among the areas overseen by management subcommittees that report to the Board; the chief AI officer owns AI governance.In production
USAAUse-case intake, governance review and AI Aware training: Each use case is evaluated for value before funding, governance analysis precedes training, and the AI Aware course reaches all employees.In production
PopularBoard oversight of AI and emerging-technology risk: The risk management committee oversees risk management for emerging technologies including AI; a Technology Committee oversees technology strategy and vendor risk.In production
WintrustAI governance framework (early stage): The CEO says governance came first; the 10-K says the bank has policies governing AI applications and websites on its network, and cannot ensure they will be effective.Rolling out
OceanFirstAutomation Transformation Office, AI governance framework and board oversight: A centralised ATO governs AI investment with ROI-based prioritisation; an AI governance framework and a model risk management policy are in place per the roadmap; the Board's Information Technology Committee oversees AI initiatives and directors received AI training.In production
Citizens Business BankAI Policy, Policy Framework and AI Governance Council: The Council, chaired by the COO with the CIO, CISO, Human Resource Director, Deputy Chief Credit Officer and an Associate General Counsel, reviews and approves AI solutions of the bank or its vendors, defines acceptable use and provides for monitoring and reporting.In production
NBTResponsible-use approach: AI paired with training and oversight to streamline recurring work, improve data quality and reinforce governance and controls.Announced
FirstSunAI as competitive risk: The 10-K says failing to keep pace with AI-enabled analytics and customer offerings could weaken its competitive position.Announced
First Financial BanksharesAI adoption risk (10-K): The 10-K flags the risk of adopting, or failing to adopt, technology such as AI; no AI system in use is named.Announced
ConnectOneBan on non-approved generative AI: Policies and governance structures prohibit employees from using non-approved generative AI applications or websites on the bank's network or devices.In production
Bread FinancialAI review of all customer calls: Andretta said AI lets Bread review all customer calls for complaint trends, which it can show regulators, and feed those trends into rep training.In production
BancFirstAI expected to grow, not yet material: The 10-K says AI use is not material at this time and is expected to grow; it names the risk categories BancFirst expects to manage but no tool or process.Announced
HilltopAI deployed 'where practical': Management says AI deployment, technology and data-platform investment are a key focus and sit inside 2026 expense guidance; no use case is named.Announced
Park NationalAI as a tool under human judgment: The chairman's shareholder letter frames AI as a tool whose value depends on the person wielding it; it sets out no policy or governance structure.Announced
National Bank HoldingsAI as an investment and competitive factor: Filings list the ability to invest in or leverage new technologies such as AI, and the success of the digital growth strategy, among factors that affect results.Announced
The BancorpAutomation and AI in the Apex 2030 operating model: The September 2026 restructuring says the bank is refining workflows and expanding automation and AI while cutting costs.Rolling out

Is there a single AI governance rule for banks?

No. In the US, AI governance is assembled from model-risk guidance (SR 26-2 and its OCC and FDIC twins), third-party guidance (SR 23-4), consumer law on automated decisions (ECOA, FCRA), state laws (Colorado, California, New York) and voluntary frameworks (NIST, Treasury). The EU AI Act is the closest thing to a single rule, and it applies to banks mainly through high-risk credit scoring from December 2, 2027.

Does model risk management cover generative AI?

Not in the US since April 17, 2026. SR 26-2 states that generative and agentic AI models are outside its scope and directs banks to broader risk-management and governance practices; the agencies have promised a request for information. In the UK the PRA's SS1/23 keeps AI and machine learning inside model risk management.

What does an examiner ask to see?

An inventory of AI systems with owners and risk tiers, the approval and validation record for each material one, the data lineage behind it, the vendor due diligence where it is bought, the monitoring and the route to a human, and evidence that the board has been told what is running and why. The pillars above map each of those to the document that asks for it.

How many of the largest US banks have disclosed AI governance arrangements?

The bank pages on this site record governance-related AI activity at most of the 100 largest US banks, from named AI committees and chief AI officers to model-data 'nutrition labels'; the section below lists them with the source for each.

When a regulator changes what governance means, you'll read it the next morning.

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