AI-Ready Governance to Be a Key Priority for Credit Unions in 2026
- Kayley Grant
- 3 days ago
- 3 min read
Guest Editorial by Kayley Grant, Regulatory Compliance Officer, ViClarity
Credit unions are staring down a paradigm shift in how financial providers define governance, risk management and compliance (GRC). With AI now pressing in on nearly every GRC process, compliance leaders will be looking for modern ways to ensure safety and soundness in the era of machine learning and intelligent automation.
Layer in the unpredictability and opaqueness of AI regulation, and it becomes clear that credit unions will need to rely on deep institutional experience as much as technical capability to steer their GRC strategy through the gray areas. Compliance ambiguity deepened in November 2025 when multiple reports indicated that the White House was considering an executive order to prevent states from enacting their own AI-specific laws. However, the patchwork of existing state AI regulations remains in effect for now, pending any future Department of Justice efforts to overturn them under the anticipated order.
In light of these pressures, the next step for credit unions is to map out practical, AI-ready GRC. Here are several considerations to guide that work.
Track how regulators are thinking about AI. Because AI rulemaking is nuanced, it will be important for compliance leaders to consider the spirit or intent of different laws, guidelines and regulations. At the moment, federal leadership is signaling a hands-off, innovation-first approach. Several states on the other hand, including Utah, Colorado, California and Texas, have enacted AI rules rooted in consumer protection. Along with tracking proposed and finalized rules across state, federal and industry bodies, teams crafting AI-ready GRC strategy should routinely monitor how regulators are talking about AI, not just what they formally publish.
Revisit the credit union’s risk appetite. Each cooperative will see the AI opportunity through a different lens. Some will embrace AI tools as they emerge; others will take a wait-and-see approach. Although moving too slowly can leave a CU behind, moving too fast can expose it to added risk. Aligning the approach to AI with an existing risk strategy will make sense for some. For others, evolving that risk strategy to remain competitive may be in order. Compliance can help by conducting a structured review of the credit union’s existing risk statement and mapping current and potential AI initiatives against it to look for any gaps.
Create a formal AI use policy. A good place to start in the development of an AI policy is by identifying those AI tools already in place across the credit union. Outline what they do right now and what they could do in the future, as well as who can use them and under what conditions. Because AI is advancing rapidly, it will be important to create a future-ready policy, one that provides guidance for revoking or limiting access as new capabilities come on board. Data, too, is a critical component for the AI policy. Clarify which data can legally and ethically be exposed to AI systems.
Evolve third-party due diligence. Many vendors are in the same boat as credit unions, relying on ever-expanding AI systems with advancing capabilities. As a result, they may not fully understand their own AI risks or downstream implications. Credit union risk teams must establish procedures for continually assessing what the AI models of their third-party partners can do, which data they use and how they learn from that data to make decisions. Contractual protections are a solid way to ensure the credit union can suspend use if a vendor’s AI tool creates new or unintended compliance exposure.
Modernize governance to support safe AI adoption
In 2026, safety and soundness won’t hinge on whether credit unions adopt AI, but on how wisely they govern it. By staying on top of regulator intent and building future-ready policies and procedures that account for rapid change, compliance leaders can empower their cooperatives to innovate safely while keeping pace with fast-moving regulator and member expectations.
Kayley Grant is a Regulatory Compliance Officer for ViClarity, a global provider of governance, risk and compliance technology and consulting solutions for credit unions. Kayley can be reached at kayley.grant@viclarityus.com.