Accountability, Resilience and Trust: the HKMA has updated its supervisory guidance on AI and announced a discussion paper on agentic AI. Credit decisions are squarely in scope.
On 15 October 2026 the Hong Kong Monetary Authority announced its "ART" framework, short for Accountability, Resilience and Trust, to promote responsible adoption of artificial intelligence in the banking sector.
The framework has three parts. The HKMA issued updated Supervisory Guidance for Responsible Adoption of AI, drawing on the second cohort of its Generative AI Sandbox. It is setting up an AI training data sharing platform with Cyberport and the University of Hong Kong. And it will publish a discussion paper on a supervisory framework for agentic AI, covering a registry of material AI agents and mechanisms for human intervention. More than 60% of the use cases in the second sandbox cohort explored agentic AI.
The guidance is addressed to authorized institutions. It describes where supervisors are heading on AI in credit, and bank SME teams will be held to it directly. Three expectations are worth translating into process terms. Accountability means a named person owns each AI use, and an AI output that informs a decision can be traced to the person who accepted it. Resilience means the process still works when the model is unavailable or wrong. Trust means the customer can be given a reason, and a reviewer can reconstruct how the answer was reached.
For credit, that points to a simple design rule: AI drafts, a person decides, and the record shows both. An AI-written credit memo section, a figure extracted from a financial statement or a flag raised by a monitoring agent should each carry its source and the name of the person who confirmed it.
The agentic AI discussion paper is the item to watch. A registry of material agents would turn "which automated steps touch a credit decision" from an internal question into a supervisory one.
Covenant Desk publishes regulatory context for Hong Kong lending operations, not legal advice. Confirm how anything here applies to your licence with your own advisers.