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Principles for Financial Market Infrastructures (PFMI)

Bank for International Settlements — Committee on Payments and Market Infrastructures (CPMI) (BIS-CPMI)
Research Complete Hallucination findings published

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Rich-narrative analysis of how AI models fail on this regulation, written for AI model providers. Includes per-finding context and remediation framing.

RegLeg tested two frontier AI models against the Principles for Financial Market Infrastructures (PFMI), the global standard for payment systems, central counterparties, and securities settlement systems published jointly by CPMI and IOSCO. The models tested were Claude Opus...

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Hallucination Shape
(2 Response Hallucination + 3 Citation Hallucination = 5 Hallucination findings)

Citation Hallucination Modes (3 failures)

Fabricated 0
Pretextual 1
Contradictory 2
Hover any mode chip for definition · methodology

Hallucination findings

2 finding cards across 2 AI Models — covering 2 Response Hallucinations + 3 Citation Hallucinations (5 hallucination failures total). Each card pairs the AI's answer against the authenticated regulator-text excerpt that contradicts it, and flags every AI-cited source as Fabricated / Pretextual / Contradictory.

Model: Claude Opus 4.7 (web search on) · published 2026-05-29 · Misattributed
RLB-H-INT-BIS-CPMI-IOSCO-PFMI-2012-Q011-Opus47
What does PFMI Annex F say about oversight of critical service providers, and what is the relationship between the 2014 CPMI-IOSCO assessment methodology document and Annex F?
Claude Opus 4.7 (web search on) answered
d123 (December 2014) is 'Cyber resilience in financial market infrastructures' — preliminary CPMI work on cyber, distinct from Annex F (the canonical cyber guidance is d146, June 2016, not d123).
This finding is being reverified by the RLB Specialist Panel.
AI's cited sources
Model: Claude Sonnet 4.6 (web search on) · published 2026-05-29 · Inference Drift
RLB-H-INT-BIS-CPMI-IOSCO-PFMI-2012-Q022-Sonnet46
What specific governance requirements does PFMI Principle 2 impose on FMI boards, and is the establishment of a risk committee a conditional recommendation or a mandatory requirement?
Claude Sonnet 4.6 (web search on) answered
KC 2.5 states that 'the board should consider establishing dedicated audit, risk, and remuneration committees' — this is conditional ('should consider'), not a hard mandate.
This finding is being reverified by the RLB Specialist Panel.

Affected audiences

These findings affect the following audiences. Click through for the case studies that aggregate findings across all regulations in this jurisdiction.

Practitioners

Company Secretaries
Practitioner case study
Lawyers
Practitioner case study
Public Auditors
Practitioner case study

Sectors × Departments

Corporate Banking × Compliance
Sector × dept case study
Investment Banking × Compliance
Sector × dept case study
Investment Banking × Governance_Cosec
Sector × dept case study
Payment Institutions × Compliance
Sector × dept case study
Payment Institutions × Governance_Cosec
Sector × dept case study
Payment Institutions × Legal
Sector × dept case study
Payment Institutions × Technology_Data
Sector × dept case study
Software Saas × Compliance
Sector × dept case study
Statutory Boards Agencies × Compliance
Sector × dept case study
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