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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.

Which agent acted, on what system, under which policy
Reconstructed after the fact, if at all
Attributed at the moment of action
Who, or what, approved the decision a client will question
An inference from logs
The decision and the approver, on the record
What the agent was refused, and why
Refusals not captured
Every refusal recorded as a durable event
Keep the record where examiners can interrogate it
Ships to a vendor cloud
Retained inside your boundary
Hand the examiner evidence in a form they can read
A bespoke log export, assembled by hand
Evidence exports in a format your examiner can read, run by your operator inside your perimeter

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.

Can you show what your agents did, on whose authority?