Stakeholder Letter - Discussion Paper on the Responsible Use of Artificial Intelligence in Bermuda's Financial Services Sector (2026-02-09)

Summary

This is a stakeholder feedback letter from the Bermuda Monetary Authority following its July 2025 Discussion Paper on the Responsible Use of Artificial Intelligence in Bermuda's financial services sector. It summarises the principal themes raised by respondents and explains how the BMA's thinking is evolving, but explicitly does not introduce any new AI-specific regulatory requirements at this time.

• Approach confirmed: The BMA will maintain an outcomes-based, principles-led and technology-neutral supervisory approach rather than prescriptive AI-specific rules.
• Integration, not duplication: AI-related risks are expected to be managed through existing frameworks for governance, conduct, risk management, cyber risk, operational resilience and third-party oversight, rather than new standalone AI regimes.
• Proportionality: Governance intensity should be aligned to the risk and impact of each AI use case; mandatory governance structures are considered unsuitable, and board accountability for AI outcomes remains unchanged.
• Bermuda market context: Expectations will be differentiated to reflect Bermuda's wholesale, institutional and cross-border market, particularly on transparency, explainability and disclosure.
• Board oversight and AI literacy: Boards are not expected to perform technical reviews but must maintain sufficient AI literacy to challenge management, set risk appetite and oversee AI risks proportionately.
• Market integrity and third-party risk: The BMA will continue assessing whether sector-specific guidance is needed for AI-related market integrity risks and third-party/vendor dependency risks, building on existing frameworks.
• International alignment: The Authority will continue monitoring global regulatory developments and engaging with international peers to support coherence for cross-border firms.

The letter states that any future enhancements to the regulatory framework arising from this ongoing analysis would be developed incrementally, proportionately, and subject to the Authority's normal consultation process. No deadlines, filings or new compliance actions are imposed by this letter itself.

Applies to

regulated entities across Bermuda's financial services sector, industry associations and other interested parties in Bermuda's financial services sector