The proliferation of agentic coding systems—software that writes software—has precipitated a structural lacuna in financial supervision. This Ordo-Causal Attribution Deficit describes the inability of existing prudential frameworks to assign legal duty, supervisory jurisdiction, and liability in chains of automated code generation that extend across days, multiple agentic nodes, and organizational boundaries. As the 2026 Agentic Coding Trends Report demonstrates, financial institutions now deploy "long-running agents" capable of building complete systems over extended periods with "minimal human intervention," while multi-agent orchestration creates emergent behaviours that defy linear causation. Current regulatory architectures assume proximate human oversight and discrete, attributable acts of programming. When autonomous agents generate code that modifies core banking systems, creates financial algorithms, or deploys customer-facing interfaces, the traditional nexus between human intent, supervisory duty, and prudential outcome fractures. This framework addresses the deficit by establishing forensic standards for agentic causation, a quantifiable risk assessment protocol, and capital-based incentives that internalize the externalities of unsupervised machine generation in financial services.
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Marcel Osmond
Queen Mary University of London
Queen Mary University of London
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Marcel Osmond (Fri,) studied this question.
synapsesocial.com/papers/699a9ded482488d673cd42e2 — DOI: https://doi.org/10.5281/zenodo.18711636