Sebastien Rousseau

Topic hub

Applied AI and agentic AI in banking

Agentic AI describes AI systems that plan and act across payments, treasury and back-office workflows under delegated authority. It matters to banks now because adoption is broad, while rules on accountability, transparency and model risk are still settling. This hub gives verified regulatory positions, reading paths by role and direct answers on governance and operations.

At a glance

The facts that matter

  • In a 2024 Bank of England and FCA survey, 75% of UK financial firms were already using AI and a further 10% planned to within three years. Source (checked 2026-11-10)
  • The EU AI Act entered into force on 1 August 2024; Annex III high-risk rules now apply from 2 December 2027 after the AI Omnibus. Source (checked 2026-11-10)
  • The European Commission lists credit scoring that can deny people a loan as an example of a high-risk AI use. Source (checked 2026-11-10)
  • The FCA does not plan extra regulations for AI and relies on existing frameworks such as the Consumer Duty and SM&CR. Source (checked 2026-11-10)
  • US model risk guidance SR 26-2 (17 April 2026) states that generative and agentic AI models are not within its scope. Source (checked 2026-11-10)
  • The FSB consulted on 12 sound practices for responsible AI adoption on 10 June 2026, including questions on agentic AI. Source (checked 2026-11-10)

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FAQ

Questions and answers

What is agentic AI in banking?

Agentic AI means AI agents that plan and carry out multi-step tasks, such as payments, treasury or back-office work, under delegated authority rather than only answering questions. The banking questions it raises are consent, liability, audit trails and interoperability.

Where is AI used in payments operations?

In fraud prevention, payment repair, routing, liquidity forecasting and compliance screening, and increasingly in controls for agent-initiated payments. The deciding factor is design discipline: which data, rails, controls and liabilities sit together.

How widely do UK financial firms use AI?

A 2024 Bank of England and FCA survey found 75% of firms already using AI, with a further 10% planning to within three years. Foundation models accounted for 17% of use cases.

When do EU AI Act high-risk rules apply to banks?

After the AI Omnibus, which entered into force on 27 July 2026, high-risk rules for Annex III systems apply from 2 December 2027. Credit scoring is listed as a high-risk use.

Did the AI Omnibus delay everything?

No. The AI Act's transparency rules took effect in August 2026, so customer-facing chatbots and generated content carry obligations now, even though the high-risk deadline moved.

Does the FCA plan AI-specific rules?

No. The FCA says it does not plan extra regulations for AI and relies on existing frameworks, including the Consumer Duty and the Senior Managers and Certification Regime.

Does US model risk guidance cover generative and agentic AI?

Not directly. SR 26-2, issued on 17 April 2026, says generative and agentic AI models are not within its scope and that a bank's wider risk management and governance practices should guide their controls.

What is the difference between human-in-the-loop and human-on-the-loop?

Human-in-the-loop means the agent cannot act without explicit human approval. Human-on-the-loop means the agent acts autonomously while a human monitors and can intervene; every high-risk agent needs a stated position on which applies.

Who is liable when an AI agent makes a payment?

That question is not yet settled, because payment law was written for transactions decided by humans. Emerging protocols try to capture the user's instructions and final approval as auditable evidence of intent before money moves.

Are there international principles for AI in finance?

The Financial Stability Board consulted in June 2026 on 12 sound practices for responsible AI adoption, covering governance and the AI lifecycle. NIST's AI Risk Management Framework, released in January 2023, is another widely used reference.