# Zions Bancorporation: Responsible AI

Source: https://www.bankingnewsai.com/banks/zions/responsible-ai
Last updated: Oct 16, 2026

*Part of the [Zions Bancorporation AI strategy profile](https://www.bankingnewsai.com/banks/zions).*

## 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. ([Zions Bancorporation (SEC filings)](https://www.sec.gov/Archives/edgar/data/109380/000010938026000046/zions-20251231.htm), [Zions Bancorporation (SEC filing)](https://www.sec.gov/Archives/edgar/data/109380/000010938026000052/zions-20260318.htm))

## Which bodies, policies and controls govern AI at Zions?

| Element | What it does | Source | Date | Sources |
| --- | --- | --- | --- | --- |
| 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 | [Zions Bancorporation (SEC filings)](https://www.sec.gov/Archives/edgar/data/109380/000010938026000046/zions-20251231.htm) |
| AI Responsible Use Policy | Developed in 2025 alongside the committee, under CRO oversight | 2026 proxy | March 19, 2026 | [Zions Bancorporation (SEC filing)](https://www.sec.gov/Archives/edgar/data/109380/000010938026000052/zions-20260318.htm) |
| Innovate2Optimize | Program established in 2025 to develop risk-management solutions using AI | 2026 proxy | March 19, 2026 | [Zions Bancorporation (SEC filing)](https://www.sec.gov/Archives/edgar/data/109380/000010938026000052/zions-20260318.htm) |
| 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 | [Zions Bancorporation (SEC filing)](https://www.sec.gov/Archives/edgar/data/109380/000010938026000052/zions-20260318.htm) |
| 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 | [Zions Bancorporation (SEC filings)](https://www.sec.gov/Archives/edgar/data/109380/000010938026000046/zions-20251231.htm), [American Banker](https://americanbanker.com/news/zions-revamped-tech-leadership-team-eyes-ai-stablecoins) |
| 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 | [Zions Bancorporation (SEC filings)](https://www.sec.gov/Archives/edgar/data/109380/000010938026000046/zions-20251231.htm) |
| Third-party AI monitoring | Vendors' AI solutions monitored for contractual and regulatory compliance | 2025 Form 10-K | February 24, 2026 | [Zions Bancorporation (SEC filings)](https://www.sec.gov/Archives/edgar/data/109380/000010938026000046/zions-20251231.htm) |
| 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 | [Zions Bancorporation (SEC filing)](https://www.sec.gov/Archives/edgar/data/109380/000010938025000052/zionsannualreport2024.pdf) |

## 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. ([Zions Bancorporation (SEC filings)](https://www.sec.gov/Archives/edgar/data/109380/000010938026000046/zions-20251231.htm))

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. ([Zions Bancorporation (SEC filings)](https://www.sec.gov/Archives/edgar/data/109380/000010938026000083/zions-20260331.htm), [Zions Bancorporation (SEC filings)](https://www.sec.gov/Archives/edgar/data/109380/000010938026000111/zions-20260630.htm))

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. ([Zions Bank](https://zionsbank.com/personal/community/our-community-feed/empowering-zions-bankers-through-technology), [Yahoo Finance](https://finance.yahoo.com/markets/stocks/articles/zions-zion-q1-2026-earnings-135526314.html))

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. ([Zions Bancorporation (SEC filing)](https://www.sec.gov/Archives/edgar/data/109380/000010938026000052/zions-20260318.htm), [Reuters](https://reuters.com/business/finance/zions-bancorps-quarterly-profit-rises-interest-income-offsets-loan-loss-2025-10-20))

## What does the Zions profile record on this topic?

| Date | Move | Detail | Sources |
| --- | --- | --- | --- |
| 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. | [Zions Bancorporation (SEC filings)](https://www.sec.gov/Archives/edgar/data/109380/000010938026000111/zions-20260630.htm), [Zions Bancorporation (SEC filings)](https://www.sec.gov/Archives/edgar/data/109380/000010938026000083/zions-20260331.htm) |
| 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. | [Investing.com (conference transcript)](https://investing.com/news/transcripts/zions-at-rbc-capital-conference-strategic-growth-amid-challenges-93CH-4553545) |
| 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. | [American Banker](https://americanbanker.com/news/zions-revamped-tech-leadership-team-eyes-ai-stablecoins) |
| 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. | [Zions Bancorporation (SEC filings)](https://www.sec.gov/Archives/edgar/data/109380/000010938026000046/zions-20251231.htm) |
| 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. | [Yahoo Finance](https://finance.yahoo.com/news/zions-zion-q4-2025-earnings-000408635.html) |
| 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. | [Reuters](https://reuters.com/business/finance/zions-bancorps-quarterly-profit-rises-interest-income-offsets-loan-loss-2025-10-20), [The Wall Street Journal](https://www.wsj.com/finance/stocks/regional-bank-worries-weigh-on-stocks-504a92a8) |
| Sep 24, 2025 | 56% of staff on generative AI | Genovate peer coaching; copilots for bankers and fraud-detection tools under construction; products 20% faster. | [American Banker](https://americanbanker.com/news/2025-the-most-powerful-women-to-watch-no-3-jennifer-smith-zions-bancorporation) |
| 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. | [Earnings call transcript (The Motley Fool)](https://fool.com/earnings/call-transcripts/2025/08/05/zions-zion-q2-2025-earnings-call-transcript) |
| 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. | [American Banker](https://americanbanker.com/news/zions-leaders-reflect-on-lessons-learned-from-11-year-core-upgrade) |

## Common questions

### 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.
## Deeper on Zions

- [What is Zions Bancorporation's AI strategy?](https://www.bankingnewsai.com/banks/zions/ai-strategy)
- [What technology stack does Zions run, and how does it support AI?](https://www.bankingnewsai.com/banks/zions/technology-stack)


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