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      Addressing the governance gap in AI for financial services

      Following a targeted supervisory review across banks, insurers and superannuation trustees, APRA confirmed that existing prudential standards already apply to AI. The gap isn't regulatory – it's governance and assurance maturity.

      In addition to addressing regulator expectations, governance and assurance mechanisms when done well can help enhance customer and colleague trust in AI.



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      Learn more about how KPMG Trusted AI can help define a responsible AI governance approach where the sophistication matches the complexity of the AI solution being implemented. 

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      Building Trusted AI in financial services

      How we can address the gaps identified by APRA


      APRA themes

      Why this matters:

      Treating AI as 'just another technology' leads to weak lifecycle governance, unclear accountability, and limited oversight, particularly for generative and agentic AI systems in critical, customer-facing processes.

      Mature governance helps deploy AI faster and with confidence, and mitigates the risk of failure, harm, and scrutiny.

      What good looks like:

      • Governance: establish a fit-for-purpose AI governance framework across the full lifecycle.
      • Accountability: define clear ownership and accountability for AI (design, deployment, monitoring, decommissioning).
      • Board oversight: uplift Board and executive AI literacy and challenge capability.
      • Transparency: implement central AI inventory and system-level documentation to document AI systems, use cases and agents.

      Why this matters:

      Current assurance approaches are insufficient: point-in-time testing misses evolving risks, detection of drift, bias, and degradation is limited, and audit and risk functions often lack specialist skills and tools.

      Continuous monitoring and assurance helps to detect drift or failures before they impact customers..

      What good looks like:

      • Monitoring: continuous monitoring that measures AI drift and decay against validated domain knowledge.
      • Assurance: assurance that runs at the same speed as the system it governs, with independent evaluation capability that assurance teams can rely on rather than replicate.

      Why this matters:

      Heavy reliance on AI providers leads to limited visibility over model and agent behaviour, opaque upstream dependencies (e.g. foundation models), and weak contractual protections and exit planning. Mapping the supply chain and confirming exit paths reduce single-vendor reliance and strengthen AI as a durable enterprise capability.

      What good looks like:

      • Supply chain visibility: establish end-to-end AI supply chain visibility.
      • Vendor governance: strengthen supplier governance and contractual controls (audit rights, transparency, change notification, incident response).
      • Risk management: implement ongoing performance, risk and compliance monitoring of providers.
      • Resilience: develop and test credible exit, substitution and portability strategies.

      Why this matters:

      AI is reshaping the threat landscape through introducing new attack vectors (e.g. prompt injection, data leakage, agent misuse), increasing the speed and scale of attacks, and exposing gaps in identity and access management for non-human actors.

      Rapid AI development is outpacing security controls, while shadow and workforce use of AI reduce visibility and control.

      Calibrated security controls enable organisations to deploy agents and AI generated code with confidence.

      What good looks like:

      • Identity & access: implement modern IAM for AI agents and non-human actors.
      • Privacy & data protection: strengthen privacy and data protection controls to prevent data loss of PII and other sensitive data through AI tools.
      • Vulnerability management: strengthen continuous vulnerability scanning, prioritisation and rapid patching.
      • Testing: enhance security testing across AI models, generated code and integrations.
      • Resilience: fallback processes and incident response for AI-supported critical operations.
      • Preventative controls: enforce technical controls to restrict unapproved AI tools and high-risk use cases.
      • Governance: establish clear policies and accountability for acceptable AI use.



      Six actions to take now


      Addressing regulator expectations, governance and assurance mechanisms when done well can help enhance customer and colleague trust in AI.

      looks_one

      Enhance board governance of AI

      Uplift your governance maturity through board and executive AI leadership programs, combining curated learning, intensive training and practical experiences to build AI fluency, drive cultural change and empower leadership in the age of AI.

      looks_two

      Continuous monitoring & observability

      Embed regulatory requirements and industry expertise in continuous monitoring solutions to validate, continuously monitor and evaluate whether AI delivers the right outcomes in your specific risk and regulatory context.

      looks_3

      Third-party AI risk management

      Embed AI risk considerations within Third Party Risk Management (TPRM) programs, update supplier contracts, monitor concentration risk and test exit and substitution arrangements.

      looks_4

      Structured AI trust reporting

      AI inventory and AI system cards provide an operational solution to close this gap by establishing a controlled inventory of AI systems and assessing them against your AI principles and related regulations and standards. 

      looks_5

      AI cyber controls

      Implement security controls for shadow AI, identity and access management for non-human actors, AI-generated code review, and penetration testing adapted for AI-specific attack paths.

      looks_6

      Cyber risk insights

      Organisations should quantify AI enabled cyber risks in financial terms, prioritise controls by risk reduction, to enable defensible investment and governance decisions.


      Ready to explore what AI can do for your business? Let’s talk AI – book a discovery workshop. 




      Trusted AI for financial services in action

      • Large Australian bank

        KPMG helped uplift a large Australian bank’s AI governance framework, identifying gaps and strengthening its ability to manage AI risk across both internal and third‑party solutions.

      • Government regulator

        KPMG developed a world first probabilistic, independence-weighted assurance engine for a government regulator, combining structured judgement and domain knowledge graphs to assess outcomes. As a result, the regulator can now focus supervisory attention on the riskiest participants.

      • AI in mergers & acquisitions (M&A)

        KPMG assessed AI‑readiness of a managed IT services platform, focusing on data, access and cyber controls critical for post‑deal integration and scale. The analysis contextualised exposure to emerging AI‑driven cyber threats and identified control gaps that could constrain post‑deal integration, regulatory confidence and scalable AI deployment, positioning remediation as both downside protection and a post‑acquisition value lever.


      KPMG Trusted AI Framework

      KPMG's strategic approach to designing, building, deploying and using AI strategies and solutions in a responsible and ethical manner.
      KPMG Trusted AI Framework


      Get in touch

      KPMG combines deep regulatory expertise with leading technology to deliver capabilities across all four APRA themes. Through partnerships with major platforms, we help organisations digitise and automate governance processes at scale.



      KPMG AI is built for the new world – where agents collaborate, impact is non-negotiable, and trust is what matters most.

      We work with our financial services clients to help them thrive in a rapidly transforming industry.

      We put people, trust and governance at the core of AI – helping organisations accelerate value with confidence, using our Trusted AI framework.


      Let’s talk AI – book a discovery workshop

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