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AI and model risk

GRA · PAGE · ai-and-model-riskGRA dossier · service level R0
GRAFinancial-system risk
Financial-system risk · AI and model risk

AI and model risk

Financial institutions increasingly rely on models they did not build and cannot fully see: credit scoring, fraud detection, catastrophe models, trading systems and, now, general-purpose AI supplied by a small number of providers. The Global Risks Alliance (GRA) examines how model failure becomes financial loss: through validation gaps, third-party concentration and weak human oversight. It works on shared, precompetitive questions of method, never on any firm's own models. See Financial-system risk.

The Global Risks AllianceRegister
  1. 01InstitutionThe Global Risks Alliance (GRA)
  2. 02Service levelR0: information and enquiries
  3. 03In briefThe short answer
  4. 04TransmissionHow model failure becomes financial loss
  5. 05Supervisory frameModel risk rules changed in 2026
  6. 06Systemic angleWhen many institutions use the same model
  7. 07QuestionsShared questions GRA works on

GRA · Institution · service level R0

01In brief

The short answer.

AI and model risk in finance is the potential for loss from models that institutions rely on but did not build and cannot fully see, such as credit scoring, fraud detection, catastrophe models, trading systems and general-purpose AI from few providers. GRA examines how validation gaps, third-party concentration and weak oversight turn model failure into loss.

02Spatial finance

From a satellite tile to an exposure update.

How satellite radar turns a flood into an exposure update. Synthetic scene; no real event or place.

How satellite radar maps a flood and updates the count of affected buildings.Synthetic scene and schematic model; no real event or place.
03Transmission

How model failure becomes financial loss.

ChannelHow the shock reaches finance
Validation gapsA model performs outside the conditions it was tested on, and losses or mispricing follow before anyone notices
Third-party concentrationMany institutions rely on the same model or AI provider, so one fault or outage is correlated across firms
HerdingSimilar models trained on similar data respond the same way to the same signal
Oversight failureAutomated outputs are acted on without a person able to understand, challenge or stop them
Data driftClimate, demographic or market shifts make historical training data a poor guide

Channels describe mechanisms, not measured strengths or probabilities.

04Supervisory frame

Model risk rules changed in 2026.

InstrumentStatus, October 2026What it covers
US revised interagency guidance on model risk management (SR 26-2)Issued April 2026 by the Federal Reserve, OCC and FDIC; supersedes SR 11-7Principles-based, risk-tailored model risk management; generative and agentic AI are stated to be outside its scope
PRA SS1/23 Model risk management principlesIn force for UK banks with internal model approval since May 2024Model identification, governance, development, validation and risk mitigants
EU AI Act, as amended by the AI OmnibusCredit-scoring high-risk obligations now apply from 2 December 2027Risk management, data governance, human oversight and documentation for high-risk AI, including creditworthiness assessment
NIST AI Risk Management FrameworkVoluntary, 2023Govern, map, measure and manage functions for AI risk
05Systemic angle

When many institutions use the same model.

Model risk becomes a stability question when the same vendor model, data set or foundation model sits behind many decisions. Catastrophe models used across reinsurers, credit scores used across lenders and market-data feeds used across trading desks can all move in the same direction at once. GRA studies that common-mode exposure at sector level: which model families are shared, what happens when their inputs shift, and what independent challenge exists.

Method guidance continues at AI and Financial Model Risk; AI oversight governance at GRF AI oversight and accountability.

06Questions

Shared questions GRA works on.

  1. 01

    Validation under compound shocks

    How should models be tested against conditions outside their history, such as compound physical and operational events?

  2. 02

    Provider dependency

    How concentrated is the industry's reliance on a small number of model and AI providers, and what fails together?

  3. 03

    Human oversight

    What does meaningful human review look like when a decision relies on a model no one in the room built?

  4. 04

    Catastrophe model uncertainty

    How should differences between hazard models be shown to financial readers, rather than averaged away?

07Boundary

Methods for the industry, not reviews of a firm.

  • GRA does not validate, approve or certify any institution's model, and issues no model rating.
  • Its outputs are shared methods and evidence, published where review and rights allow.
  • No member's confidential model information is exchanged with another.
  • Supervisory expectations remain with supervisors; GRA's cyber and operational work covers the related third-party questions.
08Connected

The same subject across the Consortium.

GRA platform

AI and Financial Model Risk

The specialist community, in development: AI and Financial Model Risk.

Science

AI science

Evidence on AI and autonomous systems from The Global Centre for Risk and Innovation (GCRI): AI and Autonomous Systems.

Governance

AI governance

Governance dialogue convened by The Global Risks Forum (GRF): AI and Digital Governance.

09Key terms

Terms used on this page.

Each term as this page uses it. Where a standard-setting body defines the term, the wording follows that body.

TermDefinition
Model riskThe potential for adverse consequences from decisions based on incorrect or misused model outputs, as SR 11-7 describes it.
Model validationIndependent testing that a model performs as intended and is fit for a stated use.
Concentration riskThe risk from dependence on a single provider or a small number of providers.
Human oversightReview of automated decisions by people with the authority and information to change them.
11Questions

Questions and answers.

Will GRA review our institution's models?
No. GRA does not perform members' own risk-management work. It develops shared methods and evidence that any institution can examine and apply under its own governance.
Does GRA set standards for AI in finance?
No. GRA sets no standard and certifies nothing. No member is required to adopt any method GRA publishes.
How can a model risk specialist contribute?
Through professional participation and working groups, once their terms are adopted. Register interest at membership@globalriskalliance.com.
The Global Risks Alliance

Start with an enquiry.

The current service level is R0: information and enquiries. An enquiry receives a reference and names the next step; applications, payments, compute allocations and registrations open only when their team, terms and review capacity exist.