EU financial-services agentic AI deployments operate under a compounded five-framework obligation surface (DORA, NIS2, MiFID II, EU AI Act, GDPR) that sits on top of general AI governance. Liability does not transfer to the vendor contractually regardless of SLA language — MiFID II conduct rules, EU AI Act deployer obligations, and DORA third-party-risk provisions place customer-facing and regulator-facing liability on the deploying financial institution. Compliance-posture and vendor-lock-in are the dominant GAUGE dimensions for the sector, scoring 15-25 points lower than cross-industry averages on first pass.
Re-review 10 Jun 2026: the five-framework surface stands. DORA, NIS2, MiFID II and GDPR remain in force unchanged; the EU AI Act layer shifts in timing only - the Digital Omnibus provisional agreement (7 May 2026) defers Annex III high-risk deployer obligations to 2 Dec 2027 while Article 50 transparency lands 2 Aug 2026, and the Act itself plus the liability allocation are untouched. No ESA agentic-AI-specific guidance redefining liability found (watch 1 silent); EBA published 'AI Act: implications for the EU banking and payments sector' (Nov 2025) and the ESAs are ramping joint CTPP oversight under DORA through 2026, both consistent with the compounded-surface reading. No enforcement action or industry contract template moving the liability-transfer boundary found. First piece in planned vertical-industry series. Cluster G anchor. 60-day review cadence. Watches unchanged.
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The claim: EU financial-services agentic AI deployments operate under a compounded five-framework obligation surface (DORA, NIS2, MiFID II, EU AI Act, GDPR) that sits on top of general AI governance. Liability does not transfer to the vendor contractually regardless of SLA language — MiFID II conduct rules, EU AI Act deployer obligations, and DORA third-party-risk provisions place customer-facing and regulator-facing liability on the deploying financial institution. Compliance-posture and vendor-lock-in are the dominant GAUGE dimensions for the sector, scoring 15-25 points lower than cross-industry averages on first pass.
About this register
The Reporting register tracks claims published from articles addressed to senior enterprise IT leaders — CIOs, IT directors, heads of platform. Claims are reviewed on a 30–90 day cadence; each review either reaffirms the claim, marks one substantive part as Partial, or marks it Not holding once the underlying evidence has been overtaken.
Recent corrections in Reporting
- AM-132 · Partial · 10 Jun 2026
One of four legs unanchored on re-review. The claim text attributes '12% of deployments clearing 300%+ ROI with 88% at or below break-even at 12-18 months' to the Stanford DEL 2026 Enterprise AI Playbook. Full-text verification on 10 Jun 2026 found no such figure in that source: the playbook (Pereira, Graylin, Brynjolfsson, Apr 2026) studies 51 successful deployments by design and contains no ROI distribution, no 300%-plus cohort, and no break-even measurement point (full finding at AM-029, correction of 10 Jun 2026). The only verified figure carrying the same 12/88 numerals is IDC research with Lenovo (via CIO.com, Mar 2025): roughly 88% of AI proof-of-concepts never reach production and roughly 12% graduate — a pilot-to-production graduation metric, not an ROI distribution. The Gartner 28%, McKinsey 23%/17%, and MIT NANDA 95% legs verify; they support a small high-performing tail and a large struggling body, but none documents the two-peak bimodal shape the claim asserts. Status Up -> Partial.
- AM-129 · Partial · 10 Jun 2026
One of three read-against anchors unanchored on re-review. The claim text cites 'Stanford Digital Economy Lab Enterprise AI Playbook (12/88 bimodal ROI distribution at 12-18 months)' and frames the realistic ROI band around 'the highest-discipline 12% cohort'. Full-text verification on 10 Jun 2026 found the playbook contains no 12/88 distribution, no bimodal ROI shape, and no 12-18-month ROI measurement point (full finding at AM-029, correction of 10 Jun 2026). The claim's core negative finding — no mid-market enterprise has produced a documented +240% ROI in 90 days under audited conditions — is unaffected; the McKinsey State of AI 2025 and MIT NANDA legs verify and continue to support it. The '12% cohort' framing has no verifiable referent. The only verified figure carrying the 12/88 numerals is IDC's pilot-graduation finding (roughly 88% of AI proof-of-concepts never reach production; via CIO.com, Mar 2025), a different metric. Status Up -> Partial.
- AM-201 · Partial · 10 Jun 2026
One of four named datasets unanchored on review. The claim text names 'Stanford DEL's 12% clearing 300%+ ROI vs 88% at or below break-even' as one of four independent datasets. Full-text verification on 10 Jun 2026 found the Stanford DEL Enterprise AI Playbook contains no such distribution — it studies 51 successful deployments by design and carries no ROI-realisation failure data (full finding at AM-029, correction of 10 Jun 2026). The McKinsey (23% scaling, 17% EBIT-attribution), Gartner (28% fully paying off), and MIT NANDA (95% no measurable P&L impact) datasets verify; the claim's spine stands on three datasets rather than four. The only verified figure carrying the 12/88 numerals is IDC's pilot-graduation finding (roughly 88% of AI proof-of-concepts never reach production; via CIO.com, Mar 2025), a different metric from an ROI distribution. Status Up -> Partial.
Reviews coming up in Reporting
- AM-063 · Holding · next +15d (27 Jun 2026)
AI agents executing financial transactions need a four-control bundle (action-approval gates by blast radius, kill-swit…
- AM-061 · Holding · next +15d (27 Jun 2026)
Production agentic-AI costs at scale routinely run multiples of POC projections, and a layered optimisation programme c…
- AM-003 · Partial · next +15d (27 Jun 2026)
GPT-5 Pro's tiered-subscription model forces enterprises to classify problems by computational difficulty — $200/month…