HighOversight Gap◐Demonstrated
Missing human oversight
Governance, Accountability & ComplianceDescription
Material decisions are made or communicated by the model without effective human review for high-impact flows.
Example scenario
AI-drafted adverse-action letters go out with no human review.
Real-world evidence◐Demonstrated
AI-specific regulatory reporting obligations (under EU AI Act, EBA stress-testing, FRB model inventories) are newly mandated and institutions are in early compliance phases; confirmed enforcement actions for failure to meet AI reporting obligations specifically—as opposed to broader model risk reporting—are still accumulating rather than an established pattern.
No public incident on record — evidence level: Demonstrated
Primary mitigations
- Human-in-the-loop for high-impact decisions
- approval gates
- reviewer training
- override authority.
Detection signals
Human-review coverage on high-impact flows; override-rate monitoring.
Mitigating controls
4 Non-agentic controls