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Qlogue Research

AI Governance & MRM
Operating Model Explorer

Should AI governance sit inside Model Risk Management, in a separate AI Risk function, or in a hybrid structure?
Map→Materiality→Governance→Operating Model→Research
Dependency Materiality
When does a dependency become material?

Traditional MRM frameworks already consider materiality, purpose, use and potential impact. This experiment asks an additional question: should the concentration and connectivity of an AI component influence the intensity of governance around it?

Exploratory — not a regulatory score

Describe the component

Dependency profile
What stands out
So what could this change?
Consider whether aggregate dependency exposure is adequately reflected in existing model classification, validation and monitoring.
Consider provider concentration, change notification, resilience and substitution capability.
Consider whether a shared component represents a common dependency across important business services.
Consider whether the component should be visible as a shared dependency rather than appearing only within each consuming application.
Consider whether existing model or AI risk appetite captures aggregate concentration in common components.

This is an exploratory framework, not a regulatory methodology. The characteristics are intended to support judgement rather than produce a mechanically calibrated risk score.

Dependency Map
From model inventory to AI system view

A traditional model inventory tells a bank which governed models exist. A dependency map adds a view of how components combine to produce a business outcome and where important shared dependencies sit.

AI Underwriting System Business owner: Retail Credit
Foundation model
Policy RAG
Bureau API
AI Underwriting
Human reviewer
Credit decision
Selected node
AI Underwriting System
System owner: Retail Credit

Consumes model, RAG, policy and bureau data; produces a recommendation used by an underwriter. Click any node to explore its ownership and governance implications.

MRMCredit RiskData RiskTechnology
What this demonstrates

The important point is not that dependencies are new. AI can make them more significant: shared foundation models, changing RAG content, third-party components and increasingly autonomous systems can allow changes in one component to affect several otherwise separately governed use cases.

A dependency map can make those relationships visible, but it is only a starting point.

Governance impact

Dependency materiality becomes useful only when it changes what the firm does: inventory, tiering, validation, monitoring, escalation or risk appetite.

What changes if dependency matters?

Dependency materiality only matters if it changes a governance decision.

A highly connected component could affect the perimeter and intensity of assurance even when the component itself has not become more technically complex. The questions below are research propositions, not current PRA requirements.

MRM activityPossible dependency-aware adaptation
InventoryRecord upstream/downstream dependencies and shared components, not only standalone model records.
TieringSupplement inherent model materiality with concentration and dependency information.
ValidationUse event-triggered reassessment when a material shared component, provider, RAG source or control changes.
MonitoringMonitor system behaviour and critical dependencies alongside model performance.
GovernanceRoute issues to MRM, Data, Technology/Cyber, TPRM, Compliance or Operational Risk according to the affected dependency.
Risk appetiteConsider aggregate/concentration measures: e.g. exposure to a common provider, common data source or shared AI component.

Could model-risk appetite change?

Potentially. The 2026 US guidance explicitly says sound practice includes assessing model risk both individually and in aggregate, including interactions, dependencies and common assumptions, data or methodologies. A dependency view suggests that appetite could therefore consider correlated exposure, not only individual-model exceptions.

The question moves from “How many high-risk models do we have?” toward “Where have we accumulated common points of failure across the model and AI estate?”

Operating model

There are three plausible ways to draw the boundary around AI. Each solves a different problem and creates a different failure mode.

Option A

Extend existing MRM

Reuses mature inventory, tiering, validation independence and governance.

  • Clear connection to existing model-risk standards
  • Avoids creating a parallel model governance framework
  • Risk: MRM becomes accountable for cyber, privacy, data, conduct and operational risks outside its expertise
Option B

Dedicated AI Risk

Creates horizontal ownership of AI-specific and system-level risks.

  • System/use-case view rather than model-only view
  • Can coordinate specialist second-line functions
  • Risk: duplicate inventories, duplicate challenge and blurred accountability with MRM
Working hypothesis
Option C

Hybrid

MRM retains model-risk standards and validation; horizontal AI governance coordinates end-to-end system assurance.

  • Specialist ownership stays with specialists
  • Common dependency map can connect decisions and reviews
  • Risk: requires explicit decision rights, common data and strong handoffs

Governance perimeter by use case

System typeLikely perimeter
Conventional ML modelPrimarily existing MRM
GenAI assistant with external model + internal dataMRM plus defined Data / Technology / TPRM review
Highly connected agentic systemCross-functional AI-system governance
Working principle

The governance perimeter should follow the risk architecture of the system, rather than being fixed once for all of “AI”.

Related research

Primary and industry sources that frame the current MRM perimeter and the emerging system-governance question.

Related research

These sources frame the debate: established MRM structure, current bank AI operating models, and the emerging argument for horizontal governance.

Established MRM is built around governance, standards, validation and the model lifecycle.Deloitte — Model Risk Management
McKinsey's 2026 survey finds mixed AI operating models and argues that AI model governance typically places MRM inside a broader horizontal framework spanning cyber, IT, legal and regulatory risk.McKinsey — Evolving MRM in the age of AI (2026)
The PRA retains model identification, governance, development/use, independent validation and mitigants as the core MRM principles, including AI/ML where it falls within model use.PRA — SS1/23
Deloitte argues that independent validation should remain independent, holistic and proportionate, while warning against turning validation into the final arbiter of every model decision.Deloitte UK — Growing importance of MRM
KPMG's 2026 summary of revised US guidance highlights aggregate model assessment and interconnectivity, not only model-by-model review.KPMG — Revised MRM guidance (2026)

The operating-model implication

Current anchorEmerging anchor
Model ownerDecision-system owner + component owners
Model inventoryDependency graph / system inventory
Fixed validation cycleRisk-based + event-triggered assurance
Validation team as testerValidation team as tester + assurance orchestrator
Model tierModel tier + dependency / blast-radius materiality
MRM committeeCross-risk AI / system governance with clear MRM decision rights

Prototype hypothesis: preserve independent challenge, but shift governance from isolated model records toward connected decision systems.