Demonstrates the need for updated model risk management frameworks in generative AI, suggesting implications for regulatory practices.
Model risk management was designed for deterministic statistical models, and 2026 regulation is openly acknowledging that it does not fit generative AI: US SR 26-2 excludes it, the UK keeps SS1/23 technology-neutral, and the EU AI Act mandates tamper-evident logging from August. Validators now need replayable lineage and an independently verifiable record, not paperwork the bank produced about itself. The Open Audit Record, a subsystem of the Mickai SIOS, signs every action before it executes into a post-quantum hash-chained ledger a regulator can verify offline without trusting the institution.Originally published at https://mickai.co.uk/articles/model-risk-management-meets-generative-ai. Mickai is a Sovereign Intelligence Operating System; the Open Audit Record signs every artificial intelligence action before it executes, post-quantum and offline-verifiable. 101 filed UK patent applications, Mickai LTD (Companies House 17166618).
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Micky Irons (2026) studied this question.