OCC Issues Risk-Based Framework for Banks’ Use of Generative AI
The OCC unveiled a supervisory framework guiding banks' use of Super Intelligence AI on Nov. 4, 2026.
Why it matters: Legal, compliance, and banking tech professionals must align with the OCC’s risk-focused expectations for AI use to ensure regulatory compliance and effective risk management.
- The OCC’s 16-component framework assists examiners in evaluating generative and agentic AI, termed Super Intelligence (SI).
- Banks are not required to create separate SI risk appetites; SI is not treated as a distinct risk category.
- Risk assessments focus on potential consequences, agency transfer, and human oversight, not SI's technical complexity.
- The OCC plans to update the framework regularly to reflect technological advances and feedback.
On November 4, 2026, the Office of the Comptroller of the Currency (OCC) announced a new supervisory framework to guide examiners in evaluating banks’ use of "Super Intelligence" (SI) technologies, including generative and agentic AI.
The framework consists of 16 components and emphasizes a risk-based approach where banks should assess SI applications by their potential consequences, transfer of agency, and the degree of human oversight—rather than by the underlying technical sophistication of the AI. According to the OCC’s supervisory bulletin, examiners are instructed not to treat SI as a separate risk category and banks are not required to define a separate risk appetite specifically for SI.
This approach allows banks to integrate SI into existing risk management frameworks without creating siloed AI risk constructs. The OCC also notes that control intensity should increase commensurately with the potential consequences of SI failure or misuse, reflecting prudential risk principles.
The OCC intends for this framework to be a living document, stating, "The OCC intends to update this examiner guide as the technology, use cases, and supervisory understanding change and mature". This flexibility is key in adapting supervision to rapidly evolving AI technologies.
Over 2,500 OCC examiners across the country will use this framework in their oversight activities, ensuring consistent and thorough evaluation of SI use in banks.
For legal, compliance, and banking IT professionals, these guidelines clarify regulatory expectations, helping align AI deployment with safety, soundness, and applicable legal standards.
By the numbers:
- 16 components — in the OCC’s AI supervisory framework
- Over 2,500 — OCC examiners nationwide who will apply the framework
- November 4, 2026 — date the OCC issued the supervisory framework
What's next: The OCC plans to update the supervisory framework regularly to address advances in SI technology and stakeholder feedback.