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OCC Gives Examiners an AI Framework, Not a Bank Rulebook

OCC Gives Examiners an AI Framework, Not a Bank Rulebook

The OCC framework guides examiners on bank AI and agentic AI use but, as reported, sets no enforceable standards for banks.

The OCC's new AI supervisory framework is, as reported, an examiner aid rather than a bank rulebook: it sets no enforceable standards or prescriptive requirements. It follows Bulletin 2026-13, which placed generative and agentic AI outside the OCC's revised model risk guidance in April 2026, so any firmer expectations await a separate process.

The Ledger Desk · 3 min read

The OCC has issued a supervisory framework to help its examiners evaluate how banks use artificial intelligence and agentic AI in ordinary business activities. PYMNTS reports that the document sets no enforceable standards or prescriptive requirements for banks. That makes it a window into examiner thinking rather than a compliance checklist, and the distinction matters for how far banks should read into it.

What the framework is, and is not

PYMNTS reports that the framework is meant to support OCC examiners when they evaluate banks' use of artificial intelligence and agentic AI in normal course business activities. According to that report, it does not establish supervisory expectations for banks and does not set out enforceable standards or prescriptive requirements. The OCC's own text of the framework was not among the primary documents reviewed for this piece, so these details are PYMNTS's account and should be read as reported, not confirmed.

What Bulletin 2026-13 left outside its scope

The OCC's Bulletin 2026-13, dated April 17, 2026, states that generative AI and agentic AI models are novel and rapidly evolving and are not within the scope of its revised model risk guidance. The bulletin rescinds Bulletin 2011-12 and other earlier model risk issuances. It also says the agencies plan to issue in the near future a request for information on model risk management that considers banks' use of AI, including generative and agentic AI.

What the OCC says banks are doing

The OCC's Spring 2026 Semiannual Risk Perspective says banks are taking a measured approach to generative and agentic AI, with usage generally limited to specific use cases with guardrails and human-in-the-loop accountability. It adds that the OCC recognizes unique challenges in using these tools. That is the supervisory backdrop for an examiner-facing document: adoption is described as cautious, and the agency's published position is descriptive rather than prescriptive.

What to watch next

The open item is the planned interagency request for information, which Bulletin 2026-13 says will consider banks' use of AI, including generative and agentic AI. The bulletin gives no date, and no publication is confirmed in the sources cited here. If it appears, it would be a route toward written expectations on these systems; until then, per PYMNTS, the framework guides examiners and binds no bank.

Does the OCC framework create new requirements for banks?
Not according to PYMNTS. It reports that the framework supports examiners and does not establish supervisory expectations, enforceable standards or prescriptive requirements for banks.
How does the framework relate to the OCC's model risk guidance?
Bulletin 2026-13 says generative and agentic AI models are novel, rapidly evolving and outside the scope of its revised model risk guidance. The framework is reported to address AI use in examinations.
What has the OCC said about a further step on AI?
Bulletin 2026-13 says the agencies plan to issue in the near future a request for information on model risk management that considers banks' use of AI, including generative and agentic AI. It gives no date.
  1. OCC Releases Supervisory Framework for Bank AI Use — PYMNTS
  2. Model Risk Management: Revised Guidance (Bulletin 2026-13) — Office of the Comptroller of the Currency
  3. Semiannual Risk Perspective, Spring 2026 — Office of the Comptroller of the Currency