Compliance · SR 26-2 · Agentic AI
SR 26-2 scoped agentic AI out. The obligation to account for what it did stayed in.
SR 26-2, the 2026 interagency model-risk guidance that supersedes SR 11-7, excluded generative and agentic AI from its model-risk scope, leaving that governance to each institution's own risk practice. The carve-out moved the rulebook, not the liability.
§ 01 The carve-out
No checklist. A broader audit burden.
SR 26-2 supersedes SR 11-7 and, in scoping generative and agentic AI out, removes the prescriptive frame for exactly the systems banks are now deploying into production. What replaces it is a direction toward broader risk governance, defined by the institution rather than the guidance.
That makes the burden heavier, not lighter. A carve-out is not an exemption from accountability.
The rulebook stopped naming the system. The obligation to account for what the system did did not stop.
§ 02 The evidence
What broader governance asks for, by construction.
The substrate makes the record a property of the action.
This material is informational, not legal or regulatory advice. The substrate produces the record; it does not by itself make an institution compliant. Assess your specific obligations with qualified counsel. Source: SR 26-2 (Federal Reserve, 17 April 2026), interagency model-risk guidance superseding SR 11-7.
§ 03 Questions
SR 26-2 and agentic AI, answered.
Does SR 26-2 cover agentic AI?
No. SR 26-2, the 2026 interagency model-risk guidance that supersedes SR 11-7, scopes generative and agentic AI out of its model-risk framework, leaving governance of those systems to each institution's own risk practice.
Is this legal or regulatory advice?
No. This material is informational. The substrate produces the record; it does not by itself make an institution compliant. Assess your specific obligations under SR 26-2 and related guidance with qualified counsel.