Regulation

Model risk management for AI agents

Model risk management was built for models you review once a year. AI agents change every week, so the evidence has to keep up.

Updated

The gap

Traditional model risk management assumes fixed inputs, a set method and a controlled change cycle. AI agents call tools, read new documents and get updated often. A validation file from last quarter can’t prove what the agent did yesterday.

The MRM lifecycle for AI agents

StageWhat examiners expectEvidence from Verus
InventoryEvery agent listed with an owner and purposeOne register of agents and their limits
ValidationSound design, tested before useDecision records from shadow testing
Ongoing monitoringPerformance tracked over timeA reliability score for every decision
Outcomes analysisResults compared with expectationsTrends across all decisions, not a sample
Change controlChanges reviewed and recordedBefore-and-after evidence on every change

Three lines of defence

  • First line runs the agent and owns its outcomes.
  • Second line validates and monitors it independently.
  • Third line tests that the controls held.

Each line needs the same facts. Verus gives them one shared, tamper-proof record.

How Verus helps

Verus scores every decision, flags drift as it happens and keeps signed evidence of each change, so validation becomes continuous instead of yearly.

General information, not legal advice. Confirm the scope of current supervisory guidance with your counsel.

Frequently asked questions

Are AI agents models under model risk guidance?

Many banks treat them that way, or as part of a model-driven process. Either way, supervisors expect them in your inventory, validated and monitored. Confirm the scope with your model risk team and counsel.

What changed with SR 26-2?

US banking agencies issued revised model risk guidance, SR 26-2, which superseded SR 11-7. Review how it treats generative and agentic AI with your counsel.

Why is yearly validation not enough for agents?

Agents change often: prompts, tools and data move every week. Ongoing monitoring of every decision closes the gap between reviews.

How does NIST AI RMF fit in?

The NIST AI Risk Management Framework adds guidance on traceability, oversight and measurement that complements model risk practice.

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