Financial Services Compliance

PRA AI Supervisory Expectations: What Firms Must Demonstrate

The PRA has not issued AI-specific rules. Instead, supervisors expect firms to apply existing frameworks, principally SS1/23 model risk management principles alongside SYSC and SMCR accountability rules, to AI and AI agent systems. Firms must be able to show model inventories, risk tiering, independent validation, ongoing monitoring, and named senior management accountability for AI-related risk.

Mapping Supervisory Principles to Technical Controls

SS1/23 principles translate into a specific set of operational controls once AI systems, and particularly autonomous AI agents, move into production.

  1. 1

    Model and Agent Inventory

    A register that includes AI/ML models and AI agents, tagged with risk tier and business use, linked to version control for traceability.

  2. 2

    Access Governance by Risk Tier

    Permission boundaries that tighten as model risk tier increases, so higher-risk AI agents operate under stricter approval workflows.

  3. 3

    Runtime Policy Enforcement

    Mechanisms that restrict AI agent actions to pre-approved decision boundaries consistent with the model's assigned risk classification.

  4. 4

    Audit Logging

    Capture of model inputs, outputs, and decision rationale sufficient to support independent validation and supervisory review requests.

  5. 5

    Drift and Behavior Monitoring

    Ongoing detection of model performance drift and anomalous agent behavior to satisfy continued-use monitoring expectations.

Evidence Firms Should Be Ready to Produce

Supervisory review under SS1/23 and related frameworks tends to focus on documentary and operational evidence rather than a single certification.

  • An up-to-date model inventory that explicitly identifies AI/ML models and AI agents with assigned risk tiers
  • Independent validation records covering performance, bias, and robustness testing prior to deployment
  • Ongoing monitoring logs demonstrating periodic revalidation and drift detection in production
  • Documented use-case boundaries and escalation procedures for autonomous AI agent decisions
  • Named senior management accountability records tied to specific AI systems
  • Third-party AI vendor and model dependency reviews aligned with existing outsourcing and operational resilience expectations

No Standalone AI Rulebook

Firms often search for a dedicated PRA AI rulebook and find none exists. The Bank of England, PRA, and FCA have consistently signaled through the AI Public-Private Forum and the 2022 DP5/22 discussion paper that AI and machine learning risks are addressed through existing regulatory frameworks rather than new AI-specific rules. This means compliance obligations for AI systems are derived, not standalone. Supervisors expect firms to extend model risk management (SS1/23), systems and controls requirements (SYSC), and senior manager accountability (SMCR) to cover AI use, including AI agents that make or influence decisions in regulated activities. For compliance leaders, this has a practical consequence: demonstrating AI compliance means demonstrating how multiple existing obligations apply jointly to AI systems, rather than pointing to a single AI certification or checklist.

SS1/23 Model Risk Management Principles Applied to AI

SS1/23 sets out five model risk management principles covering governance, model definition and risk tiering, model development, independent validation, and deployment with ongoing monitoring. Although written in general model risk terms, supervisors apply these principles to AI/ML models without exception. In practice this requires firms to maintain a model inventory that explicitly captures AI and AI agent systems, assign a risk tier based on complexity and materiality of use, and subject higher-tier models to more rigorous development and validation standards. For AI systems, independent validation extends beyond statistical accuracy checks to include assessment of bias, explainability, and robustness. Ongoing monitoring expectations under SS1/23 are not satisfied by a one-time approval; firms must demonstrate continuous performance tracking once an AI system is in production.

Accountability Under Existing Regimes

PRA supervisors expect accountability for AI-related risk to sit with an identified senior manager, consistent with the general accountability approach reflected in AIPPF and DP5/22 materials. This means firms cannot treat AI governance as a distributed or informal responsibility. A named individual should be accountable for the risks arising from a given AI system's systems and controls, in the same way accountability is assigned for other technology and operational risks. Where AI agents operate with a degree of autonomy, firms should document the permitted decision scope and the escalation triggers that route decisions back to human review, so that accountability is traceable even when a human is not directly executing each individual decision.

Applying These Expectations to AI Agents Specifically

AI agents that can take actions, call tools, or interact with other systems introduce a supervisory question that traditional statistical models did not: what happens when the system acts rather than merely predicts. SS1/23's deployment and ongoing monitoring principles apply here, but firms must translate them into controls that constrain agent behavior at runtime, not only at the point of initial validation. This includes agent identity and permissions that reflect least privilege, tool approval workflows that gate what an agent is allowed to invoke, and audit trails that record why a given action was taken. None of this requires new regulation to justify; it follows directly from applying existing model risk, systems and controls, and accountability expectations to systems that operate with greater autonomy than earlier generations of models.

Key Supervisory Reference Points

The core documents that inform current PRA and FCA expectations for AI, even in the absence of AI-specific rules.

Key supervisory reference documents for AI risk in UK financial services
ReferenceDescription
SS1/23Model risk management principles for banks, effective 17 May 2024, technology-agnostic and applicable to AI/ML models.
AIPPF Final Report2022 joint Bank of England and FCA forum identifying data, model risk, and governance as priority AI themes.
DP5/22Discussion paper testing whether existing SYSC and SMCR frameworks adequately cover AI/ML risk.

Operationalize PRA Model Risk Expectations for AI Agents

Trussed AI provides runtime governance for AI agents, including permission controls, tool approval workflows, and audit logging that support the evidence firms need for supervisory review under SS1/23.

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