Subnet345

Industries · Financial Services · Record Substrate

Your AI agents are making decisions the regulator will ask you to explain.

Financial institutions are moving agentic systems from experimentation toward production. Few have the infrastructure to govern them. When the first incident arrives, one question determines the outcome.

SR 26-2
2026 interagency model-risk guidance; supersedes SR 11-7 and scopes agentic AI out, leaving those systems to each bank's own governance practice
EU AI Act
Record-keeping and transparency obligations for high-risk AI (Art 12, Art 13)
DORA
Mandates ICT event logging, incident-trace retention, and regulator reporting; agents bear on it because they touch the ICT it governs

§ 01 Why now

Can your organization answer the audit question today?

2026 to 2027

Enforcement. Cost becomes concrete.

EU AI Act high-risk obligations for Annex III systems apply 2 December 2027, extended by the Digital Omnibus from the original 2 August 2026 trigger.

SR 26-2 supersedes SR 11-7 with its scope expressly excluding agentic AI, leaving governance of those systems to each bank's own practice.

The audit question

If a regulator asked you to reconstruct every decision your agents made last quarter, what would you show them?

§ 02 Use cases

Where the record substrate lands first.

Wealth management

Persistent agents that build governed context across every client interaction. Advisors focus on judgment. Agents handle continuity with a full audit trail.

Credit and underwriting

AI-assisted review with a decision trail reviewable by credit officers, compliance teams, and regulators. Speed with accountability, not instead of it.

Client onboarding

Agents within explicitly defined authority boundaries, with documentation at every step. Faster onboarding, cleaner compliance records, no reconstruction after the fact.

See what the substrate is made of on the product page →

§ 03 Regulatory protection

Measured against the frameworks.

Existing regulatory frameworks point toward a common expectation: AI-driven decisions must be explainable, governed, reviewable, and attributable. This material does not constitute legal or regulatory advice. Organizations should assess their specific obligations with qualified counsel.

ExpectationExplainability of AI-driven decisions
FrameworkEU AI Act
WithoutNo decision log
With Subnet345Replayable on demand
ExpectationDefined authority and accountability
FrameworkEU AI Act · SEC
WithoutNo ownership chain
With Subnet345Named, attributed approvals
ExpectationOperational resilience of the underlying ICT
FrameworkDORA
WithoutVendor-dependent
With Subnet345Portable, recoverable
ExpectationDocumented controls and governance record
FrameworkSR 26-2 · Audit
WithoutInformal
With Subnet345Versioned, defensible

Sources: SR 26-2 (Federal Reserve, 17 Apr 2026); EU AI Act (Reg (EU) 2024/1689, Art 12 and Art 13); DORA (Reg (EU) 2022/2554). Informational, not legal advice.

The question we help you answer

Can you show what your agents did, why they did it, and who approved it?