Showing clients which decisions were model-assisted

The sixth principle of the Ethical Technology Charter gives clients the right to see which decisions affecting them were model-assisted. The seventh gives any client the right to require a human decision. Neither principle survives contact with an operating business unless somebody maintains a register of models and a record of the decisions those models touched. This note describes that register, the disclosure it produces and what eighteen months of running it has shown in practice.

The model register held 41 models at 31 December 2025. Twelve of them touch a client mandate: portfolio construction, valuation support, credit scoring inside the commercial book, financial crime screening, and the mortality and yield models used in biological positions. Each entry names an accountable person, states the decision the model supports, records the date of the last back-test and states the conditions in which the model must not be used. The other 29 support internal operations.

In the six months to 31 December 2025 the group recorded 1,340 decisions inside client mandates. Two hundred and fourteen of them were model-assisted. None was automated. A model-assisted decision means a named person decided with a model output in front of them, and that the same person would have been accountable had the output been absent. The distinction is not cosmetic, and clients test it. The most common question asked is who could have overruled the model.

Eleven clients required a human review during the period. The standard is five business days and the median response was three. Two reviews changed the outcome. In the first, a credit limit set with model support was raised after a person read a supply contract for which the model held no field. In the second, a valuation was left unchanged but the reasoning was rewritten, because the objection was that the explanation was unintelligible rather than that the number was wrong.

The disclosure does not include model internals, parameters or code, and no client has asked for them. A client receives the decision, whether a model contributed to it, the name and role of the person accountable, and the route to a human review. Publishing internals would create an impression of transparency at the expense of the real thing, because a client cannot audit a specification and would reasonably assume that somebody else had done so.

The disclosure is currently assembled by hand from the register at each reporting date, which takes about 40 hours a period across three people. Programme Latitude funds a client reporting platform between 2030 and 2032 that will generate the same view from the register directly. Until then the work stays manual and the register is the control. A disclosure drawn from a register is only as honest as the register, which is why the register is audited each year.

Published 2026-04-21 by the Information & Data division. Research is prepared for eligible counterparties and does not constitute advice.