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February 28, 2026

SEC AI Examination Priorities for 2026

The SEC's Division of Examinations has made AI governance a priority for 2026. If you're a registered investment adviser, broker-dealer, or fund, expect questions about how your firm uses and governs AI tools.

What Examiners Will Ask

Based on SEC guidance and recent enforcement actions, expect these areas of inquiry:

AI Tool Inventory

  • What AI tools does your firm use?
  • Who approved them?
  • What data do they access?
  • Where is the documentation?

Policies and Procedures

  • Do you have an AI acceptable use policy?
  • How are new AI tools evaluated before adoption?
  • Who is responsible for AI governance?
  • How do you handle unapproved tools?

Client Data Protection

  • Which AI tools access client PII or financial data?
  • What are the vendor's data handling practices?
  • Is client data used for model training?
  • Where is data processed and stored?

Conflicts of Interest

  • Do AI tools create conflicts (e.g., AI recommending products where the firm has a financial interest)?
  • How are AI-generated recommendations reviewed before reaching clients?
  • Is there human oversight of AI-driven decisions?

Disclosures

  • Have you disclosed AI use to clients where required?
  • Are marketing materials generated by AI reviewed for compliance?
  • Do clients know when they're interacting with AI?

How to Prepare

Step 1: Inventory

Create a complete registry of every AI tool used across the firm. Include: tool name, vendor, use case, data access, approval status, responsible person.

Step 2: Policies

Implement an AI acceptable use policy covering: approved tools, prohibited uses, data classification, approval process, monitoring.

Step 3: Process

Build an auditable approval workflow for new AI tool requests. Every request, review, and decision should be logged with timestamps and rationale.

Step 4: Audit Trail

Ensure you can produce documentation on demand. Examiners won't accept "we handle it informally."

Step 5: Ongoing Monitoring

AI governance isn't set-and-forget. Monitor approved tools for vendor changes, new risks, and compliance drift.

ShieldAI automates SEC examination readiness for AI governance →