How does Zions govern its use of AI?
Zions governs AI through a framework 'for the responsible use and oversight of AI' overseen by a Data and AI Governance Committee of senior leaders from risk, legal, technology and data, according to its 2025 10-K, filed February 24, 2026. The committee sets policy, monitors risk, and requires AI-enabled processes to 'remain explainable and auditable'; use cases are evaluated for bias, transparency and data-privacy risk, and third-party AI is monitored for contractual and regulatory compliance. The 2026 proxy credits chief risk officer Chris Kyriakakis with overseeing the committee's development and 'a related AI Responsible Use Policy', and with an Innovate2Optimize program that builds risk-management solutions using AI. The board and its Risk Oversight Committee have spent significant time on technology risks, 'including, most recently, the growth in the use of generative artificial intelligence'. The operating rule is explicit: Zions has 'not implemented fully autonomous AI-driven systems in critical decision-making processes or client-facing activities', and all final actions are subject to human oversight and review. The bank has not published the policy itself.[1][2]
Data as of Oct 16, 2026 · Zions profile updated Oct 13, 2026 · 15 sources cited on this page · 140 banks profiled on this site · Markdown
Which bodies, policies and controls govern AI at Zions?
| Element | What it does | Source | Date |
|---|---|---|---|
| Data and AI Governance Committee | Senior leaders from risk, legal, technology and data; sets policy, monitors risk and events, maintains regulatory and ethical standards | 2025 Form 10-K | February 24, 2026[1] |
| AI Responsible Use Policy | Developed in 2025 alongside the committee, under CRO oversight | 2026 proxy | March 19, 2026[2] |
| Innovate2Optimize | Program established in 2025 to develop risk-management solutions using AI | 2026 proxy | March 19, 2026[2] |
| Board Risk Oversight Committee | Oversees technology risk, 'including, most recently, the growth in the use of generative artificial intelligence'; cybersecurity and technology are Level 1 risks | 2026 proxy | March 19, 2026[2] |
| No autonomous AI in critical or client-facing decisions | AI supports, informs or augments decisions; all final actions under human oversight and review | 2025 Form 10-K; American Banker | February and March 2026[1][3] |
| Model reviews | Use cases assessed for bias, transparency and data privacy; AI processes must stay explainable and auditable with escalation controls | 2025 Form 10-K | February 24, 2026[1] |
| Third-party AI monitoring | Vendors' AI solutions monitored for contractual and regulatory compliance | 2025 Form 10-K | February 24, 2026[1] |
| Data governance foundation | A data governance organization built during the core replacement 'that will serve us well in an era of artificial intelligence' | 2024 annual report | March 21, 2025[4] |
What AI risks does Zions disclose, and what is its stance on automation?
The 2025 10-K risk factor says Zions is 'in the early stages of integrating AI' and names hallucinations, bias inherited from training data, inadvertent disclosure of confidential information, intellectual-property infringement, lack of transparency and model drift as risks, along with AI used by threat actors 'to commit fraud, misappropriate funds, and facilitate cyberattacks'. It notes that vendors may build AI into their products in ways that indirectly affect the bank.[1]
The 2026 quarterly reports keep AI on the list of emerging technologies with 'positive and disruptive impacts' alongside stablecoins, tokenized deposits, blockchain and quantum computing, without describing new AI programs.[5][6]
The human-in-the-loop line predates generative AI. In a bank article on its pandemic-era technology, then technology chief Jennifer Smith said 'Technology is not used to replace a banker, and that's fundamentally different than national banks that focus on using technology to scale their operations.' CEO Harris Simmons described AI in credit review in April 2026 as widening the deals examined, with people reviewing what the tools flag.[7][8]
Not published: the AI Responsible Use Policy, an AI inventory or any external audit of AI controls. Zions Bancorporation, N.A. is a national bank supervised by the OCC, and it disclosed a $50 million loss on two allegedly fraudulent loans in October 2025.[2][9]
What does the Zions profile record on this topic?
The rows below are the entries of the Zions AI strategy profile that bear on this page, as of Oct 13, 2026; the profile holds the full record of 21 dated moves, 16 use cases and 24 sources.
| Use case | What the record shows | Status | Source |
|---|---|---|---|
| AI in targeted fraud-detection workflows | Named by management as an early targeted use. | In production | [3] |
| Enterprise AI platform on Google Gemini | A single platform with governance, policies and standards for enterprise use. | Rolling out | [3] |
| AI for client authentication | Named alongside fraud detection and product recommendations as long-standing AI uses. | In production | [10] |
| AI risk-factor disclosure and Data and AI Governance Committee | Human oversight of all final actions; bias, transparency and privacy reviews of models; monitoring of third-party AI; explainable and auditable AI processes. | In production | [1] |
| AI on wire-room and AML/BSA false positives | McLean (July 2025): AI is used actively to reduce false positives in the wire room and in AML/BSA alert review, freeing staff for analysis. | In production | [11] |
| AI detection tools for fraud and security issues | American Banker (September 2025): the bank is building advanced detection tools to spot fraud and security issues, alongside banker copilots and database assistants. | Rolling out | [12] |
| Date | Move | Detail | Source |
|---|---|---|---|
| Aug 6, 2026 | Q2 2026 10-Q lists AI among emerging-technology risks | The quarterly report names tokenised deposits, stablecoins, blockchain and AI as technologies whose adoption brings demand and risk; the Q1 10-Q (7 May) used the wording 'positive and disruptive impacts' and added quantum computing. Neither quarterly report describes a specific AI programme; the detail sits in the 2025 10-K. | [6][5] |
| Mar 10, 2026 | RBC conference: AI used for 40 years, offshore share to 10% | McLean says AI is in fraud work, credit presentations and client authentication and is accelerating; headcount was about 9,190 at year-end 2025 and should be well under 9,000 a year later; offshore staff rise from about 3% to about 10% by end-2026; TCS Quartz due in the innovation lab within 30 to 60 days. | [13] |
| Mar 10, 2026 | Gemini platform, document AI, and 'no autonomous AI' in client decisions | The new leadership on AI governance, unstructured-document processing and a measured stance; stablecoin trials planned. | [3] |
| Feb 24, 2026 | 2025 10-K: early-stage AI, human review, a Data and AI Governance Committee | No fully autonomous AI in critical decisions or client-facing activities; risk factor covers hallucinations, bias, confidential-data disclosure and AI-enabled fraud. | [1] |
| Jan 20, 2026 | Q4 2025 call: from exploration to a handful of AI projects | The president lists AI already in use (fraud detection, client authentication, product recommendations, financial-statement spreading, document processing), about $40 million of savings initiatives in the expense plan, and headcount below 9,300 from about 10,300 in 2019. | [10] |
| Oct 16, 2025 | $50 million loss on two loans disclosed | Alleged fraud in the California division triggers a regional-bank selloff; the bank calls it isolated. | [9][14] |
| Sep 24, 2025 | 56% of staff on generative AI | Genovate peer coaching; copilots for bankers and fraud-detection tools under construction; products 20% faster. | [12] |
| Jul 21, 2025 | Q2 2025 call: AI in AML alerts, wire-room false positives and W-9 processing | McLean says about 2% of the expense base is removed each year through continuous improvement, that AI handles the 21,000 W-9 forms and signature cards a year, cuts false positives in the wire room and AML/BSA, and supports loan spreading, credit presentations and loan reviews. | [11] |
| Aug 21, 2024 | Core replacement closes on TCS BaNCS | American Banker: selected in 2013, three phases (consumer loans 2017, commercial and construction loans 2019, deposits July 2024), about three times longer than planned; about 500 deposit products cut to about 100. Simmons says real-time processing should help catch fraud faster, and Zions plans to go deeper into AI and generative AI. | [15] |
Does Zions have a responsible AI policy?
Yes. The 2026 proxy says chief risk officer Chris Kyriakakis oversaw development of a Data and AI Governance Committee and 'a related AI Responsible Use Policy' in 2025. The policy has not been published; the 2025 10-K describes the framework it sits in.
Does Zions let AI make decisions about customers?
No, according to its filings. The 2025 10-K says Zions has not implemented fully autonomous AI-driven systems in critical decision-making or client-facing activities, uses AI to support, inform or augment decisions, and keeps all final actions under human oversight and review.
Who oversees AI risk at Zions?
Management's Data and AI Governance Committee, drawn from risk, legal, technology and data, sets policy and monitors AI risk; the chief risk officer oversaw its creation. At board level the Risk Oversight Committee oversees technology risks, including the growth in generative AI.
What AI risks does Zions list in its 10-K?
Hallucinations, bias, disclosure of confidential information, intellectual-property infringement, lack of transparency and model deterioration over time, plus AI used by threat actors to commit fraud and cyberattacks, vendors' embedded AI, and an uncertain, fast-changing legal environment for AI.
- Zions Bancorporation, N.A. Annual Report on Form 10-K for the fiscal year ended December 31, 2025
- Zions Bancorporation, N.A. 2026 Proxy Statement (DEF 14A)
- Zions' revamped tech leadership team eyes AI, stablecoins
- Zions Bancorporation 2024 Annual Report (Form ARS, chairman's letter)
- Zions Bancorporation, N.A. Quarterly Report on Form 10-Q for the quarter ended March 31, 2026
- Zions Bancorporation, N.A. Quarterly Report on Form 10-Q for the quarter ended June 30, 2026
- Empowering Zions Bankers Through Technology
- Zions (ZION) Q1 2026 Earnings Call Transcript
- Zions Bancorp's quarterly profit rises on interest income; offsets loan loss
- Zions (ZION) Q4 2025 Earnings Call Transcript
- Zions (ZION) Q2 2025 Earnings Call Transcript
- The Most Powerful Women to Watch, No. 3, Jennifer Smith, Zions Bancorporation
- Zions at RBC Capital Conference: Strategic Growth Amid Challenges
- Regional Bank Worries Weigh on Stocks
- Zions leaders reflect on lessons learned from 11-year core upgrade
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