Clarendon AI Governance Scorecard

As Irish building societies and credit unions expand their financial advisory services, they face unique AI governance challenges. Operating at scale and serving hundreds of thousands of members, these institutions must balance enterprise wide frameworks with the specific regulatory requirements for financial advice, particularly under CPC 2025 and the EU AI Act.

This interactive scorecard, based on our comprehensive 25 point gap analysis, provides a high level assessment of your division's position. It is designed to help PCF holders quantify risks related to third party platforms, retail scale outcomes monitoring, and vulnerable consumer protections. Answer the 25 questions below to generate your preliminary score.

Part A: Core Assessment (17 points)

Section 1: AI System Identification and Classification (3 points)

Q1. Complete AI System Inventory: Have you created and maintain a complete, current inventory of all AI systems used across your operations?

Yes Partial No

Q2. EU AI Act Risk Classification: Have you classified each AI system according to EU AI Act risk categories (High Risk, Limited Risk, Minimal Risk)?

Yes Partial No

Q3. DORA ICT System Classification: Have you identified which AI platforms constitute critical or important ICT services under DORA requiring operational resilience measures?

Yes Partial No

Section 2: Governance and Accountability (4 points)

Q4. PCF/CF Accountability Documentation: Have you documented which PCF/CF holders are accountable for AI governance, with clear responsibilities mapped to specific AI systems?

Yes Partial No

Q5. AI Governance Policy Framework: Have you established comprehensive AI governance policies covering permissible use, risk management, human oversight, and regulatory compliance?

Yes Partial No

Q6. Board and Senior Management Reporting: Does the Board receive regular reports on AI governance, risk management, and compliance status?

Yes Partial No

Q7. AI Governance Committee or Forum: Have you established a dedicated AI governance committee or forum with appropriate senior representation and clear terms of reference?

Yes Partial No

Section 3: Article 4 AI Literacy Compliance (3 points)

Q8. Staff Training Needs Assessment: Have you assessed AI literacy requirements for all staff working with AI systems, based on their roles and the systems they use?

Yes Partial No

Q9. Training Programme Delivery: Have you delivered AI literacy training to staff, with records of completion and competency assessment?

Yes Partial No

Q10. Ongoing Competency Maintenance: Have you established processes for maintaining AI literacy through refresher training and competency reassessment?

Yes Partial No

Section 4: Human Oversight and Explainability (4 points)

Q11. Human Oversight Protocols: Have you documented human oversight protocols for high risk AI systems showing when and how humans review AI outputs?

Yes Partial No

Q12. Explainability Frameworks: Can you explain to members and regulators how your AI systems reach specific decisions affecting individual members?

Yes Partial No

Q13. Decision Audit Trail: Do you maintain audit trails showing AI inputs, outputs, and human decisions for individual member cases?

Yes Partial No

Q14. Override and Intervention Records: Do you track when humans override AI recommendations, with documented reasons for intervention?

Yes Partial No

Section 5: Third Party and Vendor Management (3 points)

Q15. Platform Vendor AI Governance Oversight: Have you assessed the AI governance capabilities of platform vendors (core banking, loan origination, fraud detection) and obtained necessary documentation?

Yes Partial No

Q16. Contractual AI Governance Requirements: Do your contracts with AI platform vendors include specific requirements for transparency, explainability, and regulatory compliance?

Yes Partial No

Q17. Vendor Incident Management: Have you established processes for identifying and managing AI related incidents involving vendor platforms?

Yes Partial No

Part B: Institution Specific Assessment (8 points)

Section 6: Board and Volunteer Governance (Credit Unions) (3 points)

Q18. Board Level AI Literacy and Oversight: Has the Board (including volunteer directors for credit unions) received appropriate AI literacy training enabling effective strategic oversight?

Yes Partial No

Q19. Board Risk Committee AI Oversight: Does the Board Risk Committee (or equivalent) actively oversee AI related risks with appropriate expertise or external support?

Yes Partial No

Q20. Strategic AI Governance Decisions: Can the Board demonstrate it makes informed strategic decisions about AI adoption, risk appetite, and resource allocation?

Yes Partial No

Section 7: Scale and Resource Constraints (3 points)

Q21. Resource Appropriate Governance Framework: Have you established an AI governance framework proportionate to your institution's size, resources, and AI system complexity?

Yes Partial No

Q22. External Expertise Engagement: Where internal expertise is limited, have you engaged appropriate external support for AI governance, risk assessment, or technical evaluation?

Yes Partial No

Q23. Collaborative Governance Approaches: Have you explored collaborative approaches with peer institutions, sector bodies, or shared service providers to address AI governance requirements efficiently?

Yes Partial No

Section 8: Vulnerable Member Protections (2 points)

Q24. Vulnerable Member Identification: Have you established systematic processes for identifying vulnerable members who may require enhanced protections when AI systems are used in their interactions?

Yes Partial No

Q25. Enhanced Safeguards for Vulnerable Members: Have you implemented enhanced human oversight, explainability, and intervention protocols for AI decisions affecting vulnerable members?

Yes Partial No

Your Preliminary Score: 0 / 25

Based on your answers, there are significant gaps in your AI governance framework. Immediate action is recommended.

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Confidential Access

Confidential AI Governance Scorecard

Part A: Core Assessment (17 points)

Section 1: AI System Identification and Classification (3 points)

Section 2: Governance and Accountability (4 points)

Section 3: Article 4 AI Literacy Compliance (3 points)

Section 4: Human Oversight and Explainability (4 points)

Section 5: Third Party and Vendor Management (3 points)

Part B: Institution Specific Assessment (8 points)

Section 6: Board and Volunteer Governance (Credit Unions) (3 points)

Section 7: Scale and Resource Constraints (3 points)

Section 8: Vulnerable Member Protections (2 points)

Your Preliminary Score: 0 / 25

Ready to Discuss Your Results?