TLDR: Quebec’s Autorité des marchés financiers (AMF) has released draft guidelines for public consultation on the responsible use of artificial intelligence systems within the financial sector. These guidelines, open for feedback until November 7, 2025, aim to establish clear expectations for risk management, governance, and the fair treatment of clients in the deployment of AI.
The Autorité des marchés financiers (AMF) in Quebec has taken a significant step towards regulating artificial intelligence (AI) in the financial sector, publishing comprehensive draft guidelines for public consultation on July 3, 2025. This initiative positions Quebec at the forefront of a global trend towards proactive oversight of emerging technologies in finance, with stakeholders invited to submit their comments until November 7, 2025.
The proposed guidelines are designed to set specific and operational expectations for financial institutions regarding the responsible use of artificial intelligence systems (AIS). The AMF defines an AIS as ‘a machine-based system that, for explicit or implicit objectives, infers, from the input it receives, how to generate outputs such as predictions, content, recommendations, or decisions that can influence physical or virtual environments. Different AISs vary in their levels of autonomy and adaptiveness after deployment.’ These guidelines will apply broadly to licensed insurers, financial services cooperatives, licensed trust companies, and deposit-taking institutions.
A cornerstone of the AMF’s approach is a risk-based classification system. Financial institutions will be required to assess and assign a risk level to every AIS they utilize. This rating will directly influence the policies, processes, and procedures applied throughout the system’s lifecycle, encompassing governance, risk management, and client protection. Factors to consider in this assessment include technical characteristics (e.g., dynamic calibration, unstructured data, open-source code), data quality and sources, and existing controls such as bias mitigation. In cases of incomplete information, a provisional risk rating based on a conservative approach must be assigned and subsequently updated.
Governance is another critical pillar. The guidelines mandate that financial institutions implement a robust risk management framework tailored to their specific nature, size, complexity, and overall risk profile. This framework must ensure regular reviews of policies, processes, and procedures to keep pace with the rapid evolution of AI technologies. Furthermore, institutions are expected to maintain a centralized, up-to-date register of all AI systems in use, detailing their management, monitoring, and decision-making processes. Key stakeholder groups, including the board of directors, senior management, risk management, and internal auditors, will have clearly defined roles and responsibilities.
Fair treatment of clients is explicitly addressed, reaffirming existing principles while introducing AI-specific requirements. Institutions must ensure their code of ethics explicitly covers AIS use, upholding high ethical standards and respecting client rights. Active monitoring for discrimination risks is required, along with the identification of prohibited factors or proxy variables. Any problematic AIS must be promptly addressed, and all changes meticulously documented, with follow-up reports submitted to senior management.
The AMF’s guidelines also emphasize the lifecycle management of AI systems, requiring financial institutions to establish processes covering all phases from development to ongoing supervision. These processes and controls must be developed, documented, approved, and implemented proportionally to the AIS’s risk rating, with higher-risk systems facing more stringent monitoring, validation, and improvement requirements.
This Quebec initiative aligns closely with broader international standards, including principles drawn from the European Union’s Artificial Intelligence Act and the OECD’s Recommendation of the Council on Artificial Intelligence. Domestically, it complements the Office of the Superintendent of Financial Institutions (OSFI)’s Guideline B-13, which governs technology and cyber risk management for federally regulated financial institutions. This alignment is expected to help financial institutions meet global expectations for AI ethics and safety.
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Prior to these draft guidelines, the AMF has been actively engaged in the responsible development of AI, notably by signing the Montréal Declaration for responsible AI development and publishing a 2021 report titled ‘Artificial intelligence in finance – Recommendations for its responsible use,’ prepared in collaboration with Algora Lab.
