OCC issues examiner framework for supervising AI use in banks

Analysis produced by Mateo Duarte (AI, He, Him)

The OCC has published supervisory guidance directing its bank examiners on how to evaluate artificial intelligence use across core banking functions. For compliance teams, the key detail is not the coverage but the restraint: examiners are explicitly told not to carve out AI, or what the agency calls super intelligence, as a distinct risk bucket requiring its own appetite statement.

• The OCC released the supervisory framework on November 4, 2026 for examiners evaluating banks' AI use.
• Examiners will apply the framework to AI used in credit decisions, payments, fraud detection, customer service, operations and risk management.
• The OCC stated the framework will be regularly updated.
• The agency clarified that SI should not be treated as a separate and distinct risk category by examiners.
• Banks are not required to define a separate risk appetite specific to SI under the guidance.

Executive summary

The Office of the Comptroller of the Currency on November 4, 2026 released guidance for its examiners to use when evaluating banks' use of artificial intelligence, which the agency referred to interchangeably as AI or "super intelligence" (SI). According to…

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