ECB
ECB publishes observational annex on 2025 AI workshops with banks
Published
Sep 22, 2026
Effective
Aug 2, 2026
Topics
Artificial intelligence, Credit scoring, Fraud detection, Model risk management, EU AI Act, Data governance, Third-party risk, Operational resilience
Executive Summary
The ECB’s November 2025 annex reports anonymised, self-reported findings from 13 supervised banks that joined 2025 workshops on AI, focused mainly on credit scoring and fraud detection. The ECB explicitly says the material is observational, informational and not a supervisory assessment, so it does not create new binding requirements, templates or deadlines. For business purposes, however, it is a useful supervisory signal: participating banks are embedding AI into existing risk and model frameworks, keeping humans in key decision loops, using established machine-learning techniques rather than GenAI for these use cases, and building AI Act inventories and self-assessments. The annex also highlights uneven maturity in explainability, third-party dependency management, fallback arrangements and the adaptation of data governance standards to AI. Significant institutions and their AI vendors should treat the publication as a benchmark against existing model risk, outsourcing, operational resilience and RDARR controls. The main regulatory horizon remains the EU AI Act, under which most provisions apply from 2 August 2026, while the ECB notes it is not the AI Act market surveillance authority.
What Changed
Previous
No 2025 ECB workshop annex was available for banks to benchmark these specific AI use cases.
New
The annex provides non-prescriptive, informational findings and explicitly states that it is not a supervisory assessment.
Previous
The annex does not establish a previous binding benchmark for these use cases.
New
The ECB identifies common patterns: internal development, coexistence with traditional models, regular monitoring and continued human involvement.
Previous
No uniform AI governance operating model is prescribed by the annex.
New
The ECB notes that the effectiveness of emerging AI governance structures is still to be measured.
Previous
AI Act readiness was not complete across the observed sample.
New
Banks are progressing readiness work, and the EU AI Act separately provides that most provisions apply from 2 August 2026.
Previous
Existing model, data and outsourcing controls were not consistently adapted to AI-specific risks across the observed sample.
New
The ECB frames these as emerging risk management areas, particularly for data quality, explainability, cybersecurity, operational resilience and third-party risk.
Business Impact
Who is affected
Directly affected
ECB-supervised significant institutions using or planning AI in credit scoring, loan origination, credit monitoring or fraud detection.
Indirectly affected
EU bank technology, cloud, model-as-a-service, data, fraud analytics and credit analytics providers supporting those AI use cases.
Jurisdictions
Banking Union, European Union
Business processes
AI use-case approval and inventory management, Credit scoring model development, validation and monitoring, Fraud detection alert generation and investigation workflows, Human oversight and explainability controls, Third-party, cloud and outsourcing risk management, Risk data aggregation, data quality and AI data lineage controls, EU AI Act readiness and system classification
Estimated effort
Medium
Compliance risk
Medium
Affected Reports
| Field | Validation rule |
|---|
Recommended Actions
- 1AI generatedStep 1 of 7
Treat the annex as a supervisory benchmark, not a binding rule, and map its observations to existing AI, model risk, outsourcing and data governance controls.
- 2AI generatedStep 2 of 7
Refresh the AI systems inventory and use-case intake process to capture credit scoring, credit monitoring and fraud detection tools, including ownership, model type, deployment status, provider involvement and human oversight.
- 3AI generatedStep 3 of 7
Review EU AI Act self-assessments and risk classifications, particularly for creditworthiness-related AI, against Regulation (EU) 2024/1689 and retain evidence of classification rationale.
- 4AI generatedStep 4 of 7
Strengthen model validation evidence for AI credit and fraud models, including explainability approach, performance metrics, bias/error review, monitoring frequency and fallback procedures.
- 5AI generatedStep 5 of 7
Reassess cloud, vendor, open-source library and model-as-a-service dependencies for AI use cases, including continuity, cybersecurity, chain outsourcing and data privacy controls.
- 6AI generatedStep 6 of 7
Integrate AI data inputs into RDARR and data-quality governance, including golden-source usage, lineage, exception approval and data fitness for model purpose.
- 7AI generatedStep 7 of 7
Prepare concise supervisory-dialogue evidence, including AI governance roles, committee mandates, policies, KPIs, dashboards and examples of human-in-the-loop operation.
Timeline
other
2025
The ECB identifies digitalisation and new technologies as a 2025 supervisory priority, continuing previous supervisory work on digitalisation and machine learning in internal models.
other
Aug 1, 2025
ECB AI workshops were held with participating banks in three to four-hour remote or hybrid meetings.
publication
Nov 1, 2025
ECB published the annex summarising anonymised, self-reported information from the 2025 AI workshops with banks.
implementation
Date not specified
The annex reports that some banks that had not yet performed AI Act self-assessments planned to do so by 2025 year-end.
effective date
Aug 2, 2026
Most provisions of Regulation (EU) 2024/1689, the EU AI Act, apply from this date, subject to the Act’s specific exceptions and phased application provisions.
Sources
AI-generated analysis is based on the following primary sources. Always verify against the official publication.
- Supervisory briefing annexEuropean Central Bank Banking SupervisionNov 1, 2025AI workshops with banks 2025 – Annex ↗
https://www.bankingsupervision.europa.eu/ecb/pub/pdf/annex/ssm.nl251120_1_annex.en.pdf
- RegulationOfficial Journal of the European UnionJul 12, 2024Regulation (EU) 2024/1689 laying down harmonised rules on artificial intelligence ↗
https://eur-lex.europa.eu/eli/reg/2024/1689/oj
- Supervisory guideEuropean Central Bank Banking SupervisionMay 1, 2024Guide on effective risk data aggregation and risk reporting ↗
https://www.bankingsupervision.europa.eu/ecb/pub/pdf/ssm.supervisory_guides202405_riskdataaggregationreporting.en.pdf
- Supervisory priorities webpageEuropean Central Bank Banking SupervisionDate not specifiedSupervisory priorities ↗
https://www.bankingsupervision.europa.eu/banking/priorities/html/index.en.html
- GuidelinesEuropean Banking AuthorityFeb 25, 2019EBA Guidelines on outsourcing arrangements ↗
https://www.eba.europa.eu/publications-and-media/press-releases/eba-publishes-revised-guidelines-outsourcing-arrangements
Related Evidence
Verified source support for this analysis
The evidence agent checks whether the drafted finding is supported by official publications and relevant public source material.
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