On 3 February 2026 Supervisory Board member Patrick Montagner told the 10th Annual FinTech and Regulation Conference in Brussels that over 85% of ECB-supervised banks use AI and that the greatest risk facing European banks may be the innovations they fail to pursue. He warned of governance gaps in data quality, explainability and accountability, of 'reward hacking' by AI systems that optimise metrics rather than outcomes, and of concentration and geopolitical dependence on non-EU generative-AI providers. He cited EUR 4.2 billion of payment fraud across the EEA in 2024 and framed DORA, MiCAR and the AI Act as a common risk-management language.
| Document | Montagner speech: 'Encouraging innovation, managing risks' (Feb 2026) — Encouraging innovation, managing risks: the ECB's approach to digital transformation — speech by Patrick Montagner |
| Issued by | European Central Bank — Banking Supervision (SSM) |
| Type | Speech |
| Status | Final |
| Published | Feb 3, 2026 |
| Applies to | No obligations; supervisory-board-level view on AI, tokenisation and DORA for significant institutions. |
| Official source | bankingsupervision.europa.eu ↗ |
| Use cases | Generative & agentic AI · Third-party & vendor AI · Fraud detection · AI governance (general) |
What are the key points of Montagner speech: 'Encouraging innovation, managing risks' (Feb 2026)?
- Over 85% of supervised banks use AI; DORA applicable since January 2025
- EUR 4.2 billion in payment fraud reported across the EEA in 2024
- Governance gaps: data quality, explainability, accountability; 'reward hacking' risk in AI systems
- Concentration and geopolitical risk from reliance on non-EU generative-AI providers
- Tokenised deposits distinguished from stablecoins; banks should set strategies aligned with risk appetite
- DORA, MiCAR and AI Act together give supervisors and banks a common framework for cyber, AI and third-party risk
What did Montagner speech: 'Encouraging innovation, managing risks' (Feb 2026) change for banks?
It marked the ECB publicly treating under-investment in AI as a supervisory concern in its own right, while naming provider concentration outside the EU as a risk JSTs will probe in third-party assessments.
Does the ECB see not adopting AI as a risk for banks?
Yes. Montagner's February 2026 speech said the greatest risk for European banks may be the innovations they neglect, alongside the governance risks of AI they do adopt.
| Date | Document | Status |
|---|---|---|
| Jul 7, 2026 | ECB 'Dear CEO' letter on AI-enabled cybersecurity threats (SSM-2026-0301) — Addressing AI-enabled cybersecurity threats — letter from the Chair of the Supervisory Board to CEOs of significant institutions | In force |
| Jun 3, 2026 | Elderson speech: 'Strengthening operational resilience for the age of AI' (June 2026) — Strengthening operational resilience for the age of AI — speech by Frank Elderson | Final |
| Feb 24, 2026 | Machado speech: 'Technology is neutral, governance is not' (Feb 2026) — Technology is neutral, governance is not: AI adoption in the banking sector — speech by Pedro Machado | Final |
| Nov 20, 2025 | Supervision Newsletter: AI use cases for credit scoring and fraud detection (Nov 2025) — AI's impact on banking: use cases for credit scoring and fraud detection (Supervision Newsletter, November 2025) | Final |
| Nov 18, 2025 | SSM supervisory priorities 2026–28 — ECB Banking Supervision: SSM supervisory priorities for 2026–28 | In force |
| Oct 14, 2025 | Machado speech: 'Artificial intelligence and supervision: innovation with caution' (Oct 2025) — Artificial intelligence and supervision: innovation with caution — speech by Pedro Machado | Final |
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