AI Managed Services & Outsourcing Support for Financial Services
External AI Governance & Compliance Office | EU AI Act Compliance Monitoring | AI Risk Management | DORA | Regulatory Outsourcing Support
Maintain AI Compliance. Control Regulatory Risks. Stay Prepared for Supervisory Scrutiny.
Artificial intelligence is becoming an integral part of financial services. Banks, insurance companies, asset managers, investment firms and payment institutions increasingly use AI for creditworthiness assessments, insurance pricing, fraud detection, anti-money laundering, investment analysis, customer services and operational processes.
The adoption of artificial intelligence creates opportunities for efficiency and innovation. However, it also introduces ongoing responsibilities for governance, risk management, regulatory compliance and internal controls.
AI compliance is not a one-off implementation project. Financial institutions must maintain effective governance arrangements, reassess changing AI applications, monitor applicable regulatory requirements and ensure that internal controls remain appropriate and effective.
The European Union’s Artificial Intelligence Act (EU AI Act), Germany’s AI Market Surveillance and Innovation Promotion Act (KI-MIG), the Digital Operational Resilience Act (DORA) and existing financial-sector regulations require a coordinated approach to the regulatory management of artificial intelligence.
For many financial institutions, maintaining these arrangements creates additional demands on existing Compliance, Risk Management, ICT, Information Security and governance functions.
Leitner & Associates, a professional service of Andreas Leitner GmbH, provides specialist AI Managed Services & Outsourcing Support for banks, insurers, asset managers, investment firms, leasing and factoring companies, payment institutions and other regulated financial services providers.
Through our External AI Governance & Compliance Office, we support financial institutions with ongoing regulatory monitoring, AI system inventory maintenance, risk assessments, compliance controls, documentation updates, management reporting and remediation tracking.
Our services are designed to complement existing governance and control functions, provide access to specialist regulatory expertise and support sustainable compliance arrangements.
Ongoing regulatory expertise. Effective AI controls. Documented compliance.
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External AI Governance & Compliance Office
Specialist AI Compliance Support Without Building an Entirely New Internal Function
The increasing use of artificial intelligence creates ongoing operational requirements for financial institutions.
AI systems must be identified, classified and appropriately governed. Risk assessments, policies and controls need to reflect relevant developments. External AI service providers require oversight. Compliance documentation must remain current, and identified deficiencies must be monitored and addressed.
These activities often involve several organisational functions and require specialist regulatory knowledge.
For institutions with limited internal resources or growing AI portfolios, maintaining a dedicated operational AI compliance capability can be challenging.
Our External AI Governance & Compliance Office provides flexible, recurring specialist support to help financial institutions maintain and develop their AI governance arrangements.
Services can include:
- Monitoring relevant EU and national AI regulatory developments
- Maintaining AI system inventories and regulatory classification records
- Supporting periodic AI risk assessments and reassessments
- Reviewing and updating AI policies, procedures and compliance documentation
- Coordinating AI compliance monitoring and internal control activities
- Supporting AI-related DORA and ICT third-party risk management
- Monitoring regulatory implementation requirements and deadlines
- Coordinating AI literacy programmes and training documentation
- Tracking audit findings, corrective measures and remediation activities
- Preparing AI governance and compliance reports for management
- Supporting internal audit and supervisory examination preparation
The scope, responsibilities, frequency and reporting arrangements are tailored to the institution’s business model, regulatory status, AI applications and risk profile.
Our objective is to provide reliable, structured and ongoing AI compliance support while preserving the financial institution’s own governance and accountability.
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Our AI Managed Services & Outsourcing Support
1. AI Regulatory Intelligence & Compliance Monitoring
Monitor regulatory developments and identify their implications for your AI governance framework.
Artificial intelligence regulation continues to evolve through European legislation, national implementation measures, supervisory guidance, technical standards and regulatory interpretations.
Financial institutions need a structured process for identifying relevant developments, assessing their impact and determining whether changes to existing governance arrangements are necessary.
Our AI Regulatory Intelligence service supports ongoing monitoring of relevant regulatory requirements and supervisory developments.
Our services include:
- Monitoring relevant developments under the EU AI Act
- Monitoring Germany’s KI-MIG and related supervisory developments
- Tracking relevant BaFin, European Commission and European supervisory authority publications
- Monitoring AI-related regulatory developments under DORA and GDPR
- Assessing the potential impact of regulatory changes on existing AI applications
- Maintaining regulatory requirements and obligations registers
- Identifying relevant implementation deadlines and transitional arrangements
- Preparing regulatory impact assessments and management briefings
- Recommending updates to policies, procedures and controls
Typical deliverables: Regulatory updates, AI compliance newsletters, regulatory change assessments, obligations registers, management briefings and action recommendations.
Your benefit: Structured oversight of relevant regulatory developments and their potential implications for your institution.
2. AI System Inventory & Regulatory Classification Management
Maintain an accurate overview of AI systems and their applicable regulatory obligations.
An AI system inventory is a practical foundation for effective AI governance.
Financial institutions may use AI applications across numerous business functions, including lending, insurance, investment management, payments, compliance and internal administration.
New systems, changes to existing applications and modifications in their intended purpose may affect regulatory requirements and risk assessments.
Our AI Inventory Management service supports the ongoing maintenance and development of the institution’s AI system register.
Services include:
- Maintaining and updating the AI system inventory
- Recording new AI use cases and material changes
- Supporting regulatory classification reviews
- Maintaining provider and deployer role assessments
- Recording AI system ownership and responsibilities
- Linking AI applications to relevant regulatory requirements
- Tracking relevant approval and review statuses
- Maintaining documentation references and supporting evidence
- Supporting periodic inventory completeness reviews
- Identifying systems requiring regulatory reassessment
Typical deliverables: Updated AI system inventory, classification register, regulatory applicability matrix, responsibilities register and periodic inventory review report.
Your benefit: A maintained and documented overview of AI applications and their regulatory status.
3. AI Risk Assessment & Ongoing Risk Management
Monitor AI-related risks and support their continued assessment and control.
AI risks can change as systems evolve, underlying data changes, new providers are introduced or applications become increasingly embedded in business processes.
Potential risks include model errors, unreliable outputs, data quality deficiencies, discriminatory outcomes, insufficient human oversight, cybersecurity vulnerabilities and external dependencies.
We support financial institutions with recurring AI risk management activities tailored to their existing governance framework.
Services include:
- Periodic AI risk assessments and reassessments
- Maintenance of AI risk registers
- Review of risk classifications and materiality assessments
- Identification of emerging AI-related risks
- Monitoring of risk mitigation measures
- Support for model risk and control reviews
- Review of human oversight arrangements
- Coordination of risk acceptance and escalation procedures
- Maintenance of AI risk and control matrices
- Preparation of periodic risk reports
Where appropriate, these activities are integrated into existing enterprise risk management and internal control systems.
Typical deliverables: Updated AI risk register, risk assessment reports, risk and control matrix, risk action tracker and management reporting.
Your benefit: Ongoing visibility of AI-related risks, outstanding measures and changes requiring management attention.
4. AI Compliance Control Testing & Monitoring
Assess whether relevant AI compliance controls continue to operate as intended.
Effective AI governance requires the ongoing application of internal controls.
Policies and procedures alone do not demonstrate whether responsibilities are fulfilled, reviews take place or control activities operate effectively.
Our AI Compliance Monitoring service supports the structured review and testing of relevant governance and compliance controls.
Services include:
- Development and maintenance of AI compliance monitoring plans
- Periodic review of AI governance arrangements
- Testing of selected AI-related internal controls
- Review of AI approval and classification processes
- Assessment of adherence to internal AI policies
- Review of required documentation and records
- Monitoring of human oversight procedures
- Assessment of relevant third-party governance controls
- Identification and documentation of control deficiencies
- Preparation of findings and action recommendations
- Follow-up on previously identified deficiencies
The frequency and depth of monitoring depend on the institution’s risk profile, AI applications and agreed service scope.
Typical deliverables: AI compliance monitoring plan, control testing documentation, monitoring reports, findings register and corrective action recommendations.
Your benefit: Structured evidence of compliance monitoring and earlier identification of governance and control weaknesses.
Where independent assurance is required, appropriate organisational independence and segregation of duties must be maintained.
5. AI Policies, Procedures & Documentation Maintenance
Keep AI governance documentation aligned with regulatory requirements and operational developments.
AI governance documentation must reflect the institution’s current organisation, AI applications, responsibilities and applicable regulatory obligations.
Changes in legislation, business processes, AI systems or control arrangements may require existing documentation to be reviewed and updated.
Our Documentation Maintenance service provides ongoing support for policies, guidelines, procedures, process descriptions, checklists, registers and reporting templates.
Services include:
- Periodic reviews of AI governance policies
- Updates to AI risk management procedures
- Maintenance of AI system classification processes
- Review of acceptable-use and generative AI policies
- Updates to human oversight procedures
- Maintenance of AI third-party risk management documentation
- Updates to AI-related ICT control documentation
- Review of monitoring and incident procedures
- Version control and change documentation
- Coordination of document reviews and approvals
- Maintenance of associated registers and templates
Documents are adapted to the institution’s business model, internal responsibilities and regulatory framework.
Typical deliverables: Updated AI policies, procedures, process descriptions, checklists, registers, document change logs and approval records.
Your benefit: Current, consistent and traceable AI governance documentation that supports day-to-day operations and regulatory reviews.
6. AI & DORA Compliance Support
Support the ongoing management of AI-related ICT risks within your DORA framework.
Artificial intelligence systems may create ICT risks across their lifecycle, including data processing, model development, deployment, operation, monitoring and decommissioning.
Financial entities subject to DORA must manage relevant ICT risks, including risks associated with external ICT service providers.
In December 2025, BaFin published non-binding guidance on ICT risks arising from the use of AI in financial institutions.
Our AI & DORA Compliance Support service assists institutions in maintaining relevant governance and control arrangements.
Services include:
- Periodic review of AI-related ICT risk assessments
- Maintenance of AI-related ICT control documentation
- Support for ICT asset and dependency identification
- Monitoring of relevant information security controls
- Review of AI system lifecycle and change management processes
- Support for relevant ICT third-party risk assessments
- Review of AI-related incident and escalation arrangements
- Coordination of relevant resilience and continuity assessments
- Maintenance of related risk and action registers
- Preparation of AI-related DORA compliance reports
Our services complement the institution’s existing ICT Risk Management and Information Security functions.
Typical deliverables: AI-related ICT risk reports, updated control documentation, third-party risk assessments, compliance action registers and management reporting.
Your benefit: Coordinated management of AI-related ICT risks within existing DORA governance arrangements.
7. AI Third-Party Risk & Service Provider Oversight
Maintain effective oversight of external AI platforms, models and service providers.
Financial institutions increasingly rely on external AI service providers, cloud platforms, software suppliers and generative AI solutions.
These arrangements introduce dependencies and may create information security, operational resilience, data protection and regulatory risks.
Our AI Third-Party Risk Support service assists financial institutions in assessing and monitoring relevant external AI relationships.
Services include:
- Maintenance of AI third-party provider inventories
- Risk-based supplier reviews and reassessments
- Support for AI supplier due diligence
- Assessment of provider and deployer responsibilities
- Monitoring relevant contractual obligations and service arrangements
- Review of ICT and information security risks
- Support for DORA third-party risk management
- Monitoring of subcontracting and concentration risks where relevant
- Review of relevant incident and escalation processes
- Support for exit planning and continuity arrangements
- Preparation of supplier risk and compliance reporting
Where relevant, the service can support the maintenance of information required for the institution’s DORA ICT third-party register. The applicability of DORA depends on the nature of the services and contractual arrangements.
Typical deliverables: AI supplier inventory, third-party assessment reports, due diligence documentation, monitoring checklists, risk register and management reports.
Your benefit: More consistent oversight of external AI service providers and associated operational risks.
8. High-Risk AI Compliance & Monitoring Support
Maintain appropriate governance and compliance arrangements for relevant high-risk AI systems.
Certain AI applications in financial services are classified as high-risk under Annex III of the EU AI Act.
These include specified creditworthiness assessment systems and certain applications for risk assessment and pricing in life and health insurance, subject to applicable legal conditions and exceptions.
The obligations associated with high-risk AI depend on the organisation’s role as provider, deployer or another relevant operator.
We support ongoing compliance activities related to applicable high-risk AI requirements.
Services may include:
- Maintenance of high-risk AI requirements matrices
- Review of relevant risk management documentation
- Coordination of periodic compliance reassessments
- Maintenance of human oversight documentation
- Monitoring of relevant control activities
- Support for record-keeping and evidence management
- Review of relevant technical and operational documentation
- Monitoring of identified compliance deficiencies
- Support for applicable incident escalation processes
- Coordination of required documentation updates
- Review of fundamental rights impact assessments where applicable
- Support for provider or deployer monitoring responsibilities
The service is adapted to the requirements applicable to each system and operator. Provider post-market monitoring obligations must be distinguished from deployer monitoring and operational oversight responsibilities.
Typical deliverables: Updated high-risk AI compliance matrix, periodic review reports, monitoring records, evidence registers and corrective action tracking.
Your benefit: Structured support for maintaining relevant high-risk AI governance and compliance processes.
9. AI Literacy & Training Programme Administration
Maintain appropriate AI literacy measures and related training records.
Article 4 of the EU AI Act requires providers and deployers to take appropriate measures supporting AI literacy among relevant personnel and others dealing with AI systems on their behalf.
As AI applications and employee responsibilities evolve, financial institutions may need to review their training arrangements and update learning materials.
Our AI Training Administration service supports the organisation and documentation of AI literacy measures.
Services include:
- Maintenance of AI training needs assessments
- Coordination of role-specific training programmes
- Updates to AI literacy training materials
- Administration of open seminars, in-house training and eLearning
- Maintenance of training participation records
- Support for knowledge assessments
- Updating competency and training matrices
- Identification of relevant refresher training needs
- Training programme reporting
- Monitoring of outstanding training activities
Article 4 does not impose a universal annual course, specific external certification or fixed training duration. Appropriate measures depend on the organisation’s circumstances and relevant AI use cases.
Typical deliverables: AI training plan, competency matrix, training register, participation records, training status reports and updated learning materials.
Your benefit: Organised and documented AI literacy initiatives that support the institution’s regulatory and operational requirements.
10. AI Regulatory Remediation & Findings Management
Monitor identified deficiencies and support the completion of corrective measures.
AI governance reviews, internal audits, compliance assessments and supervisory examinations may identify deficiencies requiring corrective action.
Without structured follow-up, outstanding findings can remain unresolved and control weaknesses may persist.
Our AI Remediation Management Support service assists financial institutions with the monitoring, coordination and documentation of corrective actions.
Services include:
- Maintenance of audit and regulatory findings registers
- Prioritisation of identified deficiencies
- Tracking of corrective action plans
- Monitoring of agreed implementation deadlines
- Coordination of responsible business and control functions
- Escalation of overdue or ineffective measures
- Review of remediation documentation
- Support for corrective action verification
- Maintenance of remediation evidence
- Preparation of management status reports
- Support for internal audit and supervisory follow-up requests
Typical deliverables: Findings register, remediation action tracker, management status reports, supporting evidence register and remediation follow-up documentation.
Your benefit: Transparent tracking of corrective actions and a structured basis for evaluating remediation progress.
AI Managed Compliance: Typical Deliverables
Our services produce practical documentation and reporting designed to support ongoing governance, risk management and regulatory compliance.
| Deliverable | Purpose |
|---|---|
| AI Regulatory Monitoring Report | Identify regulatory developments and potential action requirements |
| AI Compliance Obligations Register | Maintain an overview of applicable requirements |
| AI System Inventory | Record and maintain AI applications and classifications |
| AI Risk Register | Monitor relevant AI risks and mitigation measures |
| AI Risk & Control Matrix | Link risks, obligations and internal controls |
| AI Compliance Monitoring Plan | Structure recurring control reviews |
| Control Testing Report | Document testing activities, results and deficiencies |
| AI Governance Documentation Updates | Maintain current policies, procedures and operating rules |
| AI Third-Party Risk Report | Support oversight of external AI providers |
| AI Literacy & Training Register | Document relevant training activities |
| Findings & Remediation Tracker | Monitor identified deficiencies and corrective actions |
| AI Compliance Management Report | Provide management with a consolidated compliance overview |
The reporting frequency, level of detail and required deliverables are determined by the agreed mandate.
Flexible AI Managed Services Engagement Models
We provide flexible arrangements designed to complement the institution’s existing governance and control functions.
Ongoing AI Compliance Support
Recurring specialist assistance for defined AI governance and compliance activities.
Suitable for financial institutions that already have established governance functions but require additional expertise or capacity.
Typical activities include regulatory monitoring, documentation updates, risk assessments, compliance reviews and management reporting.
External AI Governance & Compliance Office
A coordinated external support function covering multiple recurring AI compliance activities.
Suitable for organisations seeking a structured operating model for AI governance support, without establishing an entirely separate internal specialist team.
The service may include regulatory intelligence, AI inventory maintenance, risk management support, control monitoring, documentation maintenance and remediation tracking.
Managed AI Compliance Workstreams
Ongoing management support for individual compliance workstreams.
Suitable for institutions with clearly defined requirements, such as maintaining AI system inventories, monitoring AI-related DORA risks, coordinating high-risk AI compliance documentation or managing outstanding remediation actions.
Transition from Implementation to Managed Compliance
Continuity after the completion of an AI governance implementation programme.
Suitable for institutions that have completed initial implementation, remediation or interim management projects and require a structured transition to ongoing operations.
We support the handover of policies, registers, controls, monitoring schedules and reporting responsibilities into the agreed managed service arrangement.
Outsourcing AI Compliance: Responsibilities, Governance & Regulatory Requirements
External support does not remove the financial institution’s regulatory responsibilities.
Financial institutions may engage external specialists to perform or support defined governance, compliance and administrative activities.
However, whether a particular arrangement constitutes regulated outsourcing, an ICT third-party service or another form of external support depends on the nature of the services, contractual structure and applicable legislation.
Where DORA applies, Articles 28–30 establish requirements relevant to ICT third-party risk management and contractual arrangements.
These may include, depending on the circumstances:
- Assessment of the nature and importance of contracted services
- Due diligence of relevant service providers
- Assessment of ICT third-party and concentration risks
- Clear contractual responsibilities and service descriptions
- Appropriate service levels and reporting requirements
- Information security and data protection arrangements
- Relevant access, inspection and audit rights
- Subcontracting conditions
- Business continuity and exit arrangements
- Ongoing monitoring of the service provider
Additional requirements may arise under relevant banking, insurance, investment or payment services legislation.
Not all external regulatory consulting and compliance administration activities constitute ICT services under DORA.
Leitner & Associates supports institutions in defining appropriate service scopes, responsibilities, reporting arrangements, controls and documentation.
Management accountability, statutory obligations and appropriate oversight remain with the financial institution.
Our External AI Governance & Compliance Office supports internal accountable functions rather than automatically replacing them.
AI Managed Services for Banks, Insurers & Financial Institutions
Our services are tailored to the different regulatory frameworks, business models and AI applications found throughout the financial services industry.
Banks & Credit Institutions
Ongoing AI compliance support for creditworthiness assessments, lending, anti-money laundering, fraud detection, customer services, generative AI and risk management.
Services may include AI governance monitoring, DORA integration, control testing, regulatory updates and remediation tracking under applicable banking requirements.
Insurance Companies
Managed AI governance support covering underwriting, insurance pricing, claims management, fraud prevention and relevant high-risk AI applications in life and health insurance.
Our services consider applicable insurance governance requirements, including VAG, Solvency II and MaGo.
Fund Management Companies & Asset Managers
Ongoing AI compliance support for portfolio management, investment research, investment decision support, risk management and compliance.
Our approach reflects the institution’s regulatory obligations and existing governance framework.
Investment Firms & Financial Services Providers
Managed AI compliance activities for AI applications in investment advice, trading support, customer services, regulatory compliance and internal controls.
Relevant requirements may arise under MiFID II, WpHG, WpIG and DORA.
Leasing & Factoring Companies
AI governance and compliance support for credit assessment, receivables analysis, fraud prevention, contract review and operational automation.
Services are tailored to the organisation’s regulatory status, risk profile and AI applications.
Payment & Electronic Money Institutions
Ongoing support for AI governance, transaction monitoring, fraud detection, financial crime prevention, customer interaction and relevant ICT and third-party risks.
Our services consider applicable requirements under the EU AI Act, DORA, ZAG and payment services legislation.
FinTech, RegTech & AI Solution Providers
Managed regulatory compliance support for technology companies developing or supplying AI systems to regulated financial institutions.
Services may include regulatory monitoring, provider obligation assessments, documentation maintenance, high-risk AI compliance support and relevant monitoring arrangements.
Our Managed Compliance Methodology
Our approach is designed to provide structured recurring services with defined responsibilities, reporting arrangements and deliverables.
Step 1 — Assess the Institution’s Requirements
We review the institution’s AI applications, regulatory status, existing governance structures, internal resources and required support activities.
Outcome: Defined managed service requirements and proposed service scope.
Step 2 — Establish the Operating Model
We agree responsibilities, service processes, reporting arrangements, escalation procedures, documentation standards and relevant service levels.
Outcome: Managed service operating model and agreed responsibilities matrix.
Step 3 — Establish Compliance Baselines
We review existing AI inventories, regulatory assessments, policies, risk registers, control documentation and outstanding findings.
Outcome: Documented baseline, prioritised activities and monitoring schedule.
Step 4 — Deliver Recurring Services
We perform the agreed regulatory monitoring, documentation maintenance, risk management support, compliance reviews and reporting activities.
Outcome: Updated compliance documentation, monitoring evidence and management reports.
Step 5 — Monitor Performance & Improve
We review outstanding issues, service performance, material regulatory developments and changes to AI applications.
Outcome: Updated priorities, action tracking and recommendations for governance improvements.
Step 6 — Review the Mandate
We periodically review the scope and effectiveness of the agreed services, including whether support requirements have changed.
Outcome: Updated service scope, agreed improvements and maintained accountability arrangements.
Our objective is to establish a practical, transparent and sustainable model for recurring AI governance and compliance support.
Why Leitner & Associates?
Specialist Financial-Sector Regulatory Expertise
Leitner & Associates focuses on Governance, Risk & Compliance within the regulated financial services industry.
Our services combine knowledge of the EU AI Act and KI-MIG with an understanding of existing financial-sector governance and supervisory requirements.
Integrated AI Act & DORA Perspective
We consider AI-specific regulatory obligations alongside applicable ICT risk management, operational resilience and third-party risk requirements.
Our services are designed to complement existing governance arrangements rather than create unnecessary parallel structures.
Practical Compliance Documentation
We focus on clear policies, documented procedures, structured risk assessments, testable controls and reliable management reporting.
Continuity from Implementation to Ongoing Compliance
Our service portfolio covers AI readiness assessments, regulatory consulting, implementation, training, interim management and ongoing compliance support.
This enables institutions to address initial regulatory implementation needs and establish arrangements for continued governance and monitoring.
Experienced Professional Leadership
Leitner & Associates is led by Andreas Leitner, whose professional background includes positions at Deloitte, BNP Paribas and Allianz, together with extensive experience in Compliance, Anti-Money Laundering, Risk Management and regulatory programmes.
Our approach reflects the operational and supervisory requirements of regulated financial institutions rather than generic technology consulting alone.
Leitner & Associates is a professional service of Andreas Leitner GmbH.
Learn more: https://leitnerassociates.com
Frequently Asked Questions About AI Managed Services & Outsourcing
What are AI Managed Compliance Services?
AI Managed Compliance Services provide ongoing external specialist support for defined AI governance, regulatory compliance, risk management and control activities.
Services may include regulatory monitoring, AI system inventory maintenance, periodic risk assessments, compliance testing, documentation updates, third-party reviews, management reporting and remediation tracking.
Can banks and insurance companies outsource AI compliance activities?
Certain AI governance and compliance activities may be supported or performed externally, depending on their nature and the applicable regulatory requirements.
However, the institution remains responsible for meeting its statutory obligations.
The outsourcing classification, contractual requirements, governance arrangements and supervisory considerations must be assessed individually.
Is an External AI Governance & Compliance Office mandatory?
No. The EU AI Act does not generally require every financial institution to establish a dedicated external AI Compliance Office or appoint a standalone AI Officer.
However, organisations must meet the governance and compliance requirements applicable to their AI systems and activities.
An external support arrangement can provide specialist expertise and additional operational capacity.
Does outsourcing transfer regulatory accountability to the service provider?
No. Engaging an external service provider does not automatically transfer the financial institution’s statutory responsibilities.
In particular, Article 28(1)(a) DORA states that financial entities using contractual arrangements for ICT services remain responsible for compliance with their obligations under DORA and applicable financial services law.
Other relevant financial-sector requirements must also be considered.
Is every outsourced AI compliance service subject to DORA?
No. DORA applies to relevant ICT services and ICT third-party risk arrangements within its scope.
External services consisting solely of certain legal, regulatory, consultancy or administrative activities do not automatically constitute ICT services.
Whether DORA applies depends on the actual service and contractual arrangement.
What is the difference between AI Managed Services and AI Interim Management?
AI Interim Management typically provides temporary management or programme leadership for a defined assignment.
AI Managed Services provide recurring support for agreed operational activities, such as regulatory monitoring, documentation maintenance, risk management and compliance reporting.
An interim implementation programme can transition into an ongoing managed compliance arrangement.
Can AI system inventories and risk registers be maintained externally?
Yes. External specialists may support the maintenance of AI inventories, risk registers and regulatory classification records.
The institution should retain appropriate ownership, oversight, access to information and internal decision-making responsibilities.
Does every AI system require continuous monitoring under the EU AI Act?
The EU AI Act establishes different obligations according to the nature, classification and operator role associated with AI systems.
Specific monitoring obligations apply to certain high-risk AI systems, including relevant provider and deployer responsibilities.
The regulation does not impose one identical monitoring framework on every AI application.
Financial institutions may nevertheless need ongoing controls under applicable financial-sector and ICT risk management requirements.
Can Leitner & Associates support preparation for BaFin examinations?
Yes. Our managed compliance activities can include documentation maintenance, compliance evidence preparation, findings tracking and support for examination-related information requests.
However, the service does not constitute an official BaFin examination or guarantee any particular supervisory assessment.
Can high-risk AI compliance activities be supported externally?
Yes. External specialists may assist with compliance assessments, documentation maintenance, risk management, control monitoring and relevant impact assessment processes.
The applicable responsibilities remain dependent on the institution’s role and the specific legal requirements.
How often should AI compliance monitoring be performed?
There is no universal monitoring frequency applicable to every AI system and all compliance activities.
The appropriate frequency should reflect relevant legal requirements, the institution’s AI applications, associated risks, internal governance arrangements and changes affecting the systems.
The agreed monitoring schedule should be documented and reviewed where necessary.
What reports are provided through an AI Managed Compliance Service?
Depending on the agreed mandate, reporting may cover regulatory changes, AI inventories, risk assessments, internal controls, third-party risks, outstanding compliance deficiencies, remediation progress and management actions.
The report content and frequency are established in the service agreement.
Can existing Compliance and Risk Management departments use these services?
Yes. Our managed services are designed to complement existing internal functions.
External support can assist with specialist regulatory monitoring, defined compliance activities, documentation and operational capacity while the institution retains its governance and accountability.
Can the service be combined with AI training and consulting?
Yes. AI Managed Services can complement our AI Consulting & Implementation, AI Audit & Regulatory Readiness, AI Training & AI Literacy and Interim Management services.
The scope and roles should be structured to avoid inappropriate conflicts of interest or impairment of required independent assurance.
Maintain AI Governance Beyond Initial Implementation
Does your financial institution have the expertise, resources and processes needed to maintain effective AI governance and compliance over time?
Leitner & Associates provides specialist AI Managed Services & Outsourcing Support for banks, insurance companies, asset managers, investment firms, leasing and factoring companies, payment institutions and other regulated financial services providers.
Whether you require ongoing regulatory monitoring, AI system inventory maintenance, periodic risk assessments, documentation updates, compliance control testing, third-party oversight or remediation tracking, our services provide flexible support tailored to your institution.
Through our External AI Governance & Compliance Office, we help you maintain structured, proportionate and evidence-based AI compliance arrangements.
Maintain compliance. Manage risks. Demonstrate effective governance.
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