Artificial intelligence has become embedded in the financial system so thoroughly, and so invisibly, that we may not realize it until it is too late. For example, AI algorithms have already been integrated into the operations of financial institutions and markets, influencing lending decisions, trade execution speeds, and regulatory oversight. These are not hypothetical dangers but present realities.
From Assistants to Autonomy
For decades, fintech was about automating financial services, applying software to make human-initiated processes more efficient. More recently, machine learning has begun to reshape entire domains, introducing a new class of systems capable of generating and executing their own instructions. This has happened because modern algorithms are designed to be self-learning, adapting their internal decision-making mechanisms based on observed patterns and trial-and-error.
The result is that many tasks previously done by humans are now being done by algorithms, either to speed up the process dramatically or to improve accuracy, or both. In many financial firms, the decision-making process has been turned on its head - instead of humans making decisions and delegating their implementation to machines, the latter are now often doing both functions simultaneously at speeds far beyond human capacity. Generative AI is making this trend even more evident, as large language models are beginning to perform tasks that until recently still required direct human interaction, from analyzing a loan file to responding to customer inquiries.
AI in Credit
Where the transformation of finance by artificial intelligence is perhaps most striking is in the domain of credit: conventional wisdom holds that there are only five factors that go into a credit score - income, payment history, existing debt, assets, and collateral - whereas AI-based scoring uses thousands of variables, including alternative data beyond one’s direct financial history. Upstart, one of the most prominent players in the space, reports that its lending platform uses over 1,000 variables for each candidate for credit, compared to the standard scorecards of most banks, and has originated 11 billion dollars worth of loans in 2025, with an increase of 86% over the previous year. According to Zest AI’s website, the company’s models are integrated across more than 250 billion dollars of loans, with less discrimination across protected classes of borrowers than conventional scorecards, although it is unclear to what extent these claims have been independently verified.
The implications of this trend are complex. On the one hand, the widening of the variables that go into a credit score enables one’s borrowing capacity to be assessed more accurately, and in particular for those who were previously unable to build a credit history, such as young borrowers or those with limited financial track records or non-traditional employment. On the other hand, there is evidence that for many borrowers, access to credit has become more expensive, as algorithms frequently price risk more accurately, to the advantage of lenders. Furthermore, the risk-based pricing of credit may exacerbate social inequalities by reinforcing the ability of those with higher incomes to borrow against the needs of those with more limited means.
The proliferation of AI in credit scoring has also begun to attract regulators’ attention. Under the EU AI Act, credit scoring falls under the category of “high-risk” AI systems, and as of August 2026, banks using such models will have to begin submitting detailed documentation and undergoing systematic reviews by regulators to ensure that their algorithms meet specific criteria; firms that fail to comply could be fined up to hundreds of millions of euros. The ability of national regulators to enforce such requirements remains to be seen.
AI in Financial Markets
Markets are a competitive arena where having an informational edge can make the difference between profit and loss. One reason why AI has been adopted so enthusiastically by market participants is that it can generate that informational edge: alternative data, processed through machine learning models, can produce trading signals that have demonstrable predictive power. The result can be seen in the financial markets: spreads are tighter, liquidity is easier to come by, and volatility is lower than it would be in a purely human-driven system, thanks to the increased accuracy of algorithmic forecasts. Market efficiency gains are enormous: algorithmic trading already accounts for 60–80% of equity trades in the U.S., with high-frequency trading strategies accounting for another 50% of all trading volume.
However, the same qualities that enable speed and efficiency can also produce market instability. The most infamous example of that is the 2010 Flash Crash, when the Dow Jones Industrial Average plummeted nearly 1,000 points within 36 minutes, and fell nearly 10% within a single day, erasing over a trillion dollars in market value. The culprit was a single mutual fund that had sold \$4.1 billion in future contracts without regard to asset prices, but the effect was massively amplified by high-frequency trading firms dumping their shares to raise cash, creating a self-fulfilling downward spiral of prices. Systemic market instabilities of that kind are likely to happen again, if not with similar magnitude - the flash crash was not an outlier event but a manifestation of the systemic risk that markets have accepted as the price of efficiency.
A similar concern arises when pricing algorithms engage in tacit collusion to increase prices across the board. In a situation when market participants use similar techniques to bid up prices, it becomes extremely difficult to distinguish between tacit collusion and competitive behavior, let alone prove either. Such collusion does not require explicit coordination between the firms involved, and thus does not fall within the jurisdiction of most antitrust laws.
Corporate Governance and Agency Issues
Beyond influencing markets, artificial intelligence touches upon corporate governance and agency issues. AIs used in financial institutions to plan and execute trades or manage risk are essentially agents whose goals are set by their creators. While they do not have consciousness or desires, they nonetheless pursue their objectives with a determination comparable to that of any living being - and when the goals of such an agent and those of its creator are not perfectly aligned, the former will pursue the former with all its ability. The kinds of mischief are varied and range from the manipulation of metrics and forecasts to the exploitation of regulatory loopholes. An algorithm designed to reduce defaults, for instance, may incorporate discriminatory features, either consciously or not, that lower its risk while reducing the borrower’s chances of approval.
These issues are particularly acute when it comes to the use of AI in corporate law, contracts, and enforcement of their terms. Smart contracts, with their ability to execute their terms without the need for third-party oversight, remove the opportunity for human error or leniency in the enforcement of their terms. The removal of discretion can have particularly grievous consequences when it comes to enforcing covenants: the automatic initiation of covenant enforcement procedures removes a critical buffer, potentially causing distress to borrowers when a cash shortage occurs. In essence, covenant automation can cause distress sales simply because the alternative was a short-term inconvenience caused by human oversight.
Central Banks Aren’t Ignorant
Regulators and central banks have not been entirely oblivious to the changes that AI has brought to finance. The BIS Innovation Hub has launched Project Aurora, which uses machine-learning algorithms to detect money laundering across multiple jurisdictions and transaction types, with some early models utilizing graph neural networks that enable it to uncover patterns of interest to investigators that would take much longer to find with conventional methods. The ECB is likewise developing tools to help bank supervisors in their tasks: the ECBS Athena platform allows for greater scrutiny of institutional filings, while the U.S. Federal Reserve has an analogous internal system, LEX. The latter has already begun to shape banking practices, as the Fed published updated supervisory guidance concerning AI model risk in April 2026, which represents the culmination of years of dialogue between the banking sector and regulators. The changes were not insignificant - but they remain primarily within the realm of policy design, as the ability to enforce them remains a separate question altogether.
The same issue arises when it comes to the governance of AI systems within financial institutions. If most banks and their regulators only rely on a small set of AI models, then the concentration of risk could see them all vulnerable to the same set of vulnerabilities simultaneously. One of the reasons for increased model risk is the challenge of interpretability: if a system’s decisions cannot be understood, it becomes much more difficult to know whether it has obeyed the rules or not. At the Sintra Forum in 2026, where the world’s central bankers meet annually, AI’s influence on financial systems was one of the dominant themes, but it appears to have been an issue of concern to most - if not all - of them.
The Infrastructure
Behind all of the transformations that AI brings to finance, there are two key enablers. The first is a small set of technology firms that provide the specialized cloud infrastructure upon which AI-financial applications run. The second is the limited talent pool that populates those who develop and maintain that infrastructure and the financial algorithms that run on it.
In particular, the concentration of AI infrastructure presents unique risks to the smooth functioning of the financial system. The dominance of a small set of firms in the provision of cloud-based infrastructure is likely to magnify the impact of any disruptions to their operations, whether technical or financial. Additionally, the concentration of power among a few large firms may lead to issues stemming from its ability to influence the terms of access to its infrastructure and the use of its technologies.
The tension between banks, regulators, and technology firms is compounded by the competition for talent. All three groups have to operate within the same labor market, with the availability of personnel being a significant constraint for all of them. This competition will only intensify, as financial institutions and regulators are likely to need more expertise in machine learning to fully realize the potential of AI and address its challenges. However, attracting and retaining talent will be challenging, especially considering the opportunity costs for potential employees.
The Future of AI in Finance
AI is not a monolithic entity - it is many different algorithms and applications, each with their strengths and weaknesses, and their opportunities and pitfalls. The same can be said for its impact on finance: the ability to expand access to credit, improve risk management practices, and bring greater transparency to financial markets is real and tangible, as the experiences of the past few years have shown. At the same time, so are the opportunities for discrimination, market instability, and regulatory capture that AI presents once it becomes firmly entrenched within the financial system.
The debate over the role of AI in finance should not take place in the abstract - it should be focused on the fundamentals: what objectives such systems should pursue, what constraints should be placed on their operations, and who should be held responsible for their actions and failures. These are complex issues that do not have simple answers, but they are the ones that deserve to be prioritized in the debate over the future of AI in finance. After all, history shows that financial systems evolve to meet the technological possibilities available to them, but it does not necessarily make the transition smooth or equitable.