AI governance · computed from bank profiles; nothing on this page is written by a model. All ranked answers: /banks/leaders
On the public record as of Oct 28, 2026, 16 of the 141 large banks profiled list the EU AI Act among the regimes that bear on their AI programme. Ranked by linked documents, the top 5 are ING (3 linked documents), Santander US (2 linked documents), Banco Santander (2 linked documents), BBVA (2 linked documents) and BNP Paribas (2 linked documents). ING's strongest evidence: ING's 20-F says it is implementing AI governance and model-risk controls ahead of high-risk obligations phasing in during 2026 and 2027; credit-scoring and instant lending decisions are the….
141 banks profiled (120 US, 21 non-US) · 16 with matching evidence · ranked answer, not a comparison
Which of the large banks fall under the EU AI Act, according to their profiles?
| # | Bank | Linked documents | Why it applies (from the profile) | Status | Date | On this site | Sources |
|---|---|---|---|---|---|---|---|
| 1 | ING | 3 | ING's 20-F says it is implementing AI governance and model-risk controls ahead of high-risk obligations phasing in during 2026 and 2027; credit-scoring and instant lending decisions are the… | Non-US group (Netherlands) | Oct 25, 2026 | ING · regulators → | Regulation (EU) 2024/1689 · EBA factsheet: AI Act implications for the EU banking and payments sector |
| 2 | Santander US | 2 | Group-wide AI tools and credit models are within the EU AI Act's scope for the parent. | US bank | Oct 25, 2026 | Santander US · regulators → | Regulation (EU) 2024/1689 · EBA factsheet: AI Act implications for the EU banking and payments sector |
| 3 | Banco Santander | 2 | The annual report says the group promotes compliance with the EU AI Act as it extends model risk to AI systems; credit-scoring and similar uses for EU customers are high-risk under the Act. | Non-US group (Spain) | Oct 25, 2026 | Banco Santander · regulators → | Regulation (EU) 2024/1689 · EBA factsheet: AI Act implications for the EU banking and payments sector |
| 4 | BBVA | 2 | BBVA built its AI Express course around the EU AI Act and cites the Act in its responsible-AI framework; Blue, credit-analysis tools and any EU credit-scoring models fall within the Act's risk tiers. | Non-US group (Spain) | Oct 25, 2026 | BBVA · regulators → | Regulation (EU) 2024/1689 · EBA factsheet: AI Act implications for the EU banking and payments sector |
| 5 | BNP Paribas | 2 | BNP Paribas says its responsible-AI principles are implemented in compliance with the AI Act, and its AI Risk Committee monitors AI Act compliance; credit-memo, KYC and customer-assistant use cases… | Non-US group (France) | Oct 25, 2026 | BNP Paribas · regulators → | Regulation (EU) 2024/1689 · EBA factsheet: AI Act implications for the EU banking and payments sector |
| 6 | Deutsche Bank | 2 | Credit-scoring and similar AI used for EU customers is high-risk under the EU AI Act; the mortgage instant-decision and Corporate Bank credit tools sit in that territory. | Non-US group (Germany) | Oct 25, 2026 | Deutsche Bank · regulators → | Regulation (EU) 2024/1689 · EBA factsheet: AI Act implications for the EU banking and payments sector |
| 7 | HSBC | 2 | Credit-scoring and similar AI used for EU customers is high-risk under the EU AI Act, which reaches HSBC's EU entities and any EU-facing models built in the group's hubs. | Non-US group (United Kingdom) | Oct 25, 2026 | HSBC · regulators → | Regulation (EU) 2024/1689 · EBA factsheet: AI Act implications for the EU banking and payments sector |
| 8 | Société Générale | 2 | Credit-scoring and similar AI used for EU customers is high-risk under the AI Act; the group's half-year report says the scope of the AI Regulation remains unprecise and that it is carrying out the… | Non-US group (France) | Oct 25, 2026 | Société Générale · regulators → | Regulation (EU) 2024/1689 · Regulation (EU) 2026/1744 (Digital Omnibus on AI) |
| 9 | UBS Group AG | 2 | UBS's 20-F says 2025 data-protection developments were dominated by new AI rules, including the first enforcement of the EU AI Act; EU-facing credit and client-scoring AI would be high-risk under… | Non-US group (Switzerland) | Oct 25, 2026 | UBS Group AG · regulators → | Regulation (EU) 2024/1689 · EBA factsheet: AI Act implications for the EU banking and payments sector |
| 10 | JPMorgan | 1 | EU operations: credit scoring is high-risk from December 2, 2027; transparency duties since August 2026. | US bank | Oct 25, 2026 | JPMorgan · regulators → | Regulation (EU) 2024/1689 |
| 11 | Citi | 1 | The largest cross-border footprint of the US banks; EU credit scoring is high-risk from December 2, 2027. | US bank | Oct 25, 2026 | Citi · regulators → | Regulation (EU) 2024/1689 |
| 12 | State Street | 1 | Luxembourg and EU fund servicing bring EU AI Act deployer duties and DORA into scope. | US bank | Oct 25, 2026 | State Street · regulators → | Regulation (EU) 2024/1689 |
| 13 | Amex | 1 | Global card operations: EU transparency duties for AI interactions since August 2026. | US bank | Oct 25, 2026 | Amex · regulators → | Regulation (EU) 2024/1689 |
| 14 | Deutsche Bank (U.S.) | 1 | Group AI systems built in Frankfurt fall under the EU AI Act's obligations for credit scoring and other high-risk uses. | US bank | Oct 25, 2026 | Deutsche Bank (U.S.) · regulators → | Regulation (EU) 2024/1689 |
| 15 | Barclays | 1 | The 20-F flags the EU AI Act as a source of new duties for AI systems, including general-purpose models, in a group whose EU clients are served mainly by Barclays Bank Ireland PLC. | Non-US group (United Kingdom) | Oct 25, 2026 | Barclays · regulators → | Regulation (EU) 2024/1689 |
| 16 | MUFG | 1 | AI used for EU clients by the planned Amsterdam universal bank, for example in credit decisions, would fall under the EU AI Act's high-risk rules. | Non-US group (Japan) | Oct 25, 2026 | MUFG · regulators → | Regulation (EU) 2024/1689 |
Each row quotes one record from bank profiles; the “On this site” link opens the bank's own page or sub-page with every source. Banks absent from the table have nothing matching on the record this site holds.
How is this ranked?
Data: the 141 bank profiles on this site (lib/banks), every entry dated and sourced: the "Regulators" section, which names each regime and why it applies, with links to the tracker's documents.
Rule: Banks whose regulators list contains the eu-ai-act authority. Score = tracker documents the entry links; ties by assets.
Counts: 16 of 141 profiled banks qualify; 3 distinct sources cited in the table. Data checked 2026-10-28; ranking template updated 2026-10-30.
What are the caveats?
Banks absent from the table have nothing matching on the record this site holds, which is not evidence that they do nothing. Each row links the bank's own page, where every entry carries its sources.
Which bank ranks first?
ING Groep N.V. leads with 3 linked documents: ING's 20-F says it is implementing AI governance and model-risk controls ahead of high-risk obligations phasing in during 2026 and 2027; credit-scoring and instant lending decisions are the…. Santander US is second with 2.
How many large banks list the EU AI Act as a relevant regime?
16 of the 141 profiled banks (120 US, 21 non-US groups). Among those listed, 6 are US banks and 10 non-US groups.
What counts, and what does not?
Banks whose regulators list contains the eu-ai-act authority. Score = tracker documents the entry links; ties by assets. Source: the 141 bank profiles on this site (lib/banks), every entry dated and sourced: the "Regulators" section, which names each regime and why it applies, with links to the tracker's documents.
Is this a measure of capability?
No. Every row is a sourced fact on the public record: what the bank, a regulator, a filing or an independent outlet has put on the record. The page does not rate how well anything works.
When was this checked, and how often does it update?
The data behind the table was last checked on 2026-10-28 (bank profiles). The page recomputes whenever that dataset changes and is republished with the site; it is never edited by hand.
When any of these banks moves on AI, you'll read it the next morning.
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