Lawyers working on the CPMI-IOSCO Principles for Financial Market Infrastructures (PFMI, 2012) are increasingly relying on AI to draft 2-page board memos on FMI governance obligations, generate client-facing summaries of PFMI Principle 2 Key Considerations, prepare partner-level briefings on disclosure-framework responses, and validate committee-mandate language against the regulator's published Key Considerations. The PFMI framework is the global standard for systemically important payment systems, central counterparties, and securities settlement infrastructures, and the document's structure makes it particularly amenable to AI summarisation: numbered Principles, numbered Key Considerations, and lettered annexes that the model can address by number.
That surface structure is also what makes the failure mode the RegLeg Brief Specialist Panel records here invisible at runtime: the document is regularly cited by Key Consideration number in board papers, disclosure-framework returns, and counterparty representations, which means a misattributed citation does not register as a substantive error in the draft, it registers as a competent regulatory paragraph that the reader will not check against the regulator's primary text unless something else prompts the verification.
Two frontier AI models tested by the RegLeg Brief Specialist Panel produced confidently wrong reconstructions of the PFMI's governance and oversight architecture under Principle 2 (governance) and Annex F (oversight expectations for critical service providers). The Panel records one finding in the class the team labels "Source-Credit Misattribution", in which the models stated a substantively plausible governance position and pinned it to a named Key Consideration that the published PFMI text does not support. The finding identifiers are RLB-H-INT-BIS-CPMI-IOSCO-PFMI-2012-Q022-Sonnet46.
For Lawyers, the failure shape matters because the work product is client memos on FMI board obligations, legal opinions on PFMI self-assessment responses, drafted board terms of reference, and counterparty representations on governance compliance, all of which travel under the firm's name to a board, supervisor, counterparty, or public reviewer who can locate the cited Key Consideration and check it against the regulator's primary text.
Lawyers who paste AI output into a legal opinion or a client-facing compliance memo are the population most exposed to a fabricated Key Consideration citation that the reader will check against the PFMI primary text the moment a counterparty or supervisor disputes the position.
The Panel documents the finding identifiers RLB-H-INT-BIS-CPMI-IOSCO-PFMI-2012-Q022-Sonnet46. The AI subjects under test were Claude Sonnet 4.6, each running with web search enabled, mirroring the workflow most practitioners run when they ask an assistant a Principle 2 or Annex F question. The verbatim regulator text is held as primary substrate (R2-REGULATION-d101a_PFMI_main_text.pdf). Each finding card sets out the exact strings the model produced, the verbatim regulator excerpt the model's output contradicts, and the failure-class label the RegLeg Brief Specialist Panel assigns.
The records are open-access; AI labs named in any finding have an unconditional right of reply, and the Specialist Panel will document any factual correction or contextual response alongside the original finding.
This is the consolidated view of findings. Click the Citation IDs or 'see details →' on any item for the full details for each finding.
A lawyer advising on FMI board mandates or PFMI self-assessment responses who relies on this output will attribute a soft risk-committee recommendation to PFMI KC 5. KC 5 actually addresses the roles and responsibilities of management. The misattribution embeds a citation that does not check out against the regulator's text; if a counterparty, regulator, or reviewer locates KC 5 and finds it speaks to management rather than committee structure, the lawyer's PI exposure is direct.
Every finding on this page compares an AI subject's account of the rule against the regulator's verbatim text from the regulator's own portal. Both are linked. Each delta, its root causes, and impact analysis are documented and published with immutable Citation IDs.