Executive briefingAI in banking

Open-source AI in banks: adopting it without importing the risk

Open models, agent frameworks and MCP connectors are now part of almost every bank’s AI stack. The licence, supply-chain and regulatory questions they raise are answerable — but only if intake is designed for AI, not just for software.

8 min read By · Executive briefing
17 of 18
widely used finance-AI repositories we checked had no published OpenSSF Scorecard result12

Key takeaways

  • Model licences are not open-source licences: an MIT-licensed repository can depend on weights under a community licence with use restrictions, such as Llama’s 700-million-user clause97.
  • Supply-chain evidence is sparse: 17 of 18 prominent finance-AI repositories we checked had no public OpenSSF Scorecard result, so banks must generate their own12.
  • Regulation has firmed up: EU GPAI obligations have applied since 2 August 2025, high-risk obligations for Annex III systems now start on 2 December 2027, and DORA already governs ICT third-party risk234.
  • The FINOS AI Governance Framework offers a ready-made industry catalogue of 23 AI risks and mitigations to anchor an intake process15.

Open-source AI arrives in a bank by many doors. A data scientist downloads open weights to fine-tune a classifier. An engineering team adopts an agent framework. A business unit installs an MCP server to connect an assistant to market data. Each is reasonable on its own. Together they create a portfolio of third-party AI components that most banks’ software intake processes were not designed to see, let alone assess.

The good news is that the questions are well understood and the tools to answer them exist — many of them open source too. The challenge is to extend existing software governance to cover three things that are new with AI: licences on models and data as well as code, provenance of artefacts that cannot be read like source code, and regulatory obligations that attach to models and their providers.

Licence risk: code, weights and data are licensed separately

Traditional open-source compliance asks whether a package’s licence is OSI-approved and compatible with how the bank will use it. AI adds layers. FinGPT is a good illustration: its repository is MIT-licensed, but its published sentiment models are LoRA fine-tunes of Llama 2 and ChatGLM2 base models9, which carry their own terms. Llama’s community licences are not OSI licences; the Llama 3.1 licence, for instance, requires any licensee whose products had more than 700 million monthly active users on the release date to request a separate licence from Meta, which Meta may grant at its sole discretion7.

The Open Source Initiative’s Open Source AI Definition 1.0 sets a higher bar still: to qualify, a system must make available its code and parameters under OSI-approved terms and sufficiently detailed information about its training data for a skilled person to build a substantially equivalent system8. Few popular models meet it. And metadata cannot be taken on trust: GitHub’s API reports no recognisable licence for OpenBB, while the repository’s LICENSE file states that all files are licensed under Apache 2.010. Licence review has to read the files, the model cards and the base-model chain.

Supply-chain security: provenance before performance

Model files, prompts, agent skills and MCP servers are executable in effect, even when they are not code in form. A connector with access to a bank’s data and credentials deserves the scrutiny of any privileged integration. MCP adoption makes this pressing: the reference servers repository alone has 90,771 stars19.

OpenSSF Scorecard is the most widely used automated signal of open-source project hygiene. It scores projects from 0 to 10 on checks such as code review, pinned dependencies, signed releases and maintenance, and runs a weekly scan of the one million most critical open-source projects11. We queried its public API on 1 October 2026 for 18 widely used finance-AI repositories — including TradingAgents, OpenBB, ai-hedge-fund, anthropics/financial-services, FinGPT, FinRobot, FINOS Legend, FINOS AI Governance Framework, FINOS CDM, MCP reference servers, LangGraph, CrewAI, two bank-published repositories, financial-datasets/mcp-server, IBM AMLSim and NVIDIA garak — and found a published result for only one, Microsoft’s AutoGen12. Exhibit 1 shows that result alongside the general-purpose AI libraries that do appear.

Exhibit 1

Security hygiene data exists for core AI libraries, not for most finance-AI projects

OpenSSF Scorecard results (0–10) from the public API, queried 1 October 2026

RepositoryAggregate scoreMaintainedCode reviewPinned dependenciesResult date
openai/openai-python7.9101092026-09-28
huggingface/transformers6.510932026-09-28
pytorch/pytorch6.41010n/a2022-10-26
langchain-ai/langchain5.810282026-09-28
microsoft/autogen5.60602026-09-28
17 other finance-AI repositories checkedNo published result––––

Note: A missing result means the project is not in Scorecard’s public dataset, not that it is insecure; Scorecard can be run on any public repository. The pytorch/pytorch result is stale (2022).

Source: Open Source Security Foundation, “OpenSSF Scorecard public API results for selected AI repositories (api.securityscorecards.dev, queried by DaasLabs)” (2026)

Two lessons follow. First, absence of evidence is the norm, so banks must run Scorecard (or equivalent) themselves at intake and on a schedule. Second, the checks catch real signals: AutoGen scores 0 on ‘Maintained’12, consistent with its README notice that it is now in maintenance mode and will receive no new features16. Lifecycle risk is live elsewhere too — Protect AI’s LLM Guard, a popular LLM security toolkit, is now archived and no longer maintained17.

Provenance tooling for AI artefacts is maturing. CycloneDX’s ML-BOM records models, datasets and their provenance alongside software components13, and Sigstore’s model-transparency project provides signing and verification for ML models14. Red-teaming tools such as NVIDIA’s garak, an LLM vulnerability scanner with 9,394 stars, can be built into pre-production testing18.

What regulators expect

In the EU, obligations for providers of general-purpose AI models have applied since 2 August 2025 and were not moved by the Digital Omnibus2. The Omnibus, published as Regulation (EU) 2026/1744 and in force since 27 July 2026, defers high-risk obligations for Annex III systems — which include creditworthiness assessment — to 2 December 20273. Open-source status helps only at the margin: Article 53(2) exempts providers of models released under a free and open-source licence with public weights from some documentation duties, but not those of models with systemic risk1. A bank that fine-tunes and deploys an open model is still accountable for how it uses it.

DORA, applicable since 17 January 2025, requires financial entities to manage ICT third-party risk across all ICT services, and to keep a register of information on those arrangements4. On 18 November 2025 the ESAs published their first list of critical ICT third-party providers, 19 in total, for direct EU oversight56. That oversight does not transfer the bank’s own responsibility for assessing its providers6 — and open-source components, which often have no contractual provider at all, need an owner inside the bank.

Exhibit 2

The regulatory clock for open-source AI in EU banks

Key dates and what they mean for adopting open models and agent components

DateRequirementRelevance to open-source AISource
17 Jan 2025DORA appliesICT third-party risk management and register of information cover AI services and components4
2 Aug 2025EU AI Act GPAI provider obligations applyOpen-licence exemption is partial and excludes systemic-risk models21
18 Nov 2025First 19 critical ICT third-party providers designatedDirect oversight of major providers; banks keep responsibility for their own assessments56
27 Jul 2026Digital Omnibus on AI (Reg. 2026/1744) in forceAmends AI Act timelines3
2 Dec 2027High-risk obligations for Annex III systemsCovers uses such as creditworthiness assessment built on open models3

Note: EU-focused; banks outside the EU should map equivalent model risk and third-party guidance.

Source: NicFab, “Digital Omnibus on AI: Regulation (EU) 2026/1744 is published in the Official Journal” (2026)

A practical intake checklist

The FINOS AI Governance Framework, developed by practitioners from across the industry, catalogues 23 AI risks — 11 operational, 9 security and 3 regulatory — with preventative and detective mitigations mapped to the EU AI Act, NIST, OWASP and ISO 4200115. It is a sound spine for an intake process. We would add seven gates specific to open-source components:

  • Licence chain: code, weights, base model, training data and outputs, read from the files and model cards rather than platform metadata107.
  • Project health: Scorecard results, last push, maintainer identity, maintenance or archive notices111617.
  • Provenance: signed artefacts where available and an ML-BOM entry for every model and dataset1413.
  • Connector privileges: least-privilege credentials and network egress controls for each MCP server or tool.
  • Adversarial testing: prompt-injection and data-leakage testing before production18.
  • Regulatory classification: AI Act role and risk tier, plus DORA register entry14.
  • Named owner and exit plan: who patches, monitors and, if needed, replaces the component.
For executives

What this means for your bank

  1. Extend the software bill of materials to an AI bill of materials covering models, datasets, prompts, agent skills and MCP connectors.
  2. Make licence review read the base-model chain and model cards, not just repository metadata.
  3. Run OpenSSF Scorecard and adversarial tests at intake and on a schedule, with thresholds that trigger review.
  4. Record open-source AI components in the DORA register of information and assign each a named internal owner.
  5. Adopt the FINOS AI Governance Framework risk catalogue as the common language between technology risk, model risk and procurement.
Put it to work

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Sources

  1. 1
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  3. 3
  4. 4
  5. 5
  6. 6
  7. 7
    Llama 3.1 Community License Agreement (opens in a new tab) Meta (meta-llama/llama-models on GitHub), 23 July 2024
  8. 8
    The Open Source AI Definition 1.0 (opens in a new tab) Open Source Initiative, 28 October 2024
  9. 9
  10. 10
  11. 11
    OpenSSF Scorecard (opens in a new tab) Open Source Security Foundation (GitHub), 1 October 2026
  12. 12
  13. 13
  14. 14
  15. 15
  16. 16
  17. 17
  18. 18
  19. 19

Figures are drawn from the cited public sources. Opinions labelled “DaasLabs point of view” are our own.

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