Company Secretaries supporting boards exposed to the CPMI Harmonised ISO 20022 Data Requirements (Updated Report) are increasingly using AI to draft board papers on the governance lineage of payment-system standards, generate director-onboarding notes on cross-border payments policy obligations, and prepare regulatory horizon-scanning entries on CPMI workstreams. The same tools validate the attribution of standard-setting authority in committee minutes.
Two frontier AI models tested by the RLB Specialist Panel on the workflows company secretaries use to support advice on the CPMI Harmonised ISO 20022 Data Requirements (Updated Report) produced one discrete hallucination bound to regulator-issued source text. The Panel records a single recurring failure class: Source-Credit Fabrication across the set. Questions were prepared by the Specialist Panel based on real practical AI usage in the workflows company secretaries use AI for, and each finding is bound to verbatim regulator-issued source text held as primary substrate.
For Company Secretaries, each hallucination has a direct operational consequence in the board paper, director-onboarding note, or horizon-scanning entry. The Panel's testing surfaces CPMI working-group chair misattribution. Where these errors flow into a deliverable, the exposure is board-pack error that compounds across multiple committee cycles before it surfaces in a director question or supervisory review. The pattern is uniform across the set: the AI returns a confident, sourced-looking answer that conflicts in a load-bearing specific with the regulator's verbatim text, and the error survives a first-pass review precisely because the surface form is plausible.
The Panel records each hallucination with the regulator's primary substrate held as the anchor, so the corrective text is available alongside the failure.
The Specialist Panel records the citation IDs as follows: RLB-H-INT-BIS-CPMI-ISO-20022-HARMONISATION-UPDATED-2026-Q004-Sonnet46 (Claude Sonnet 4.6 (web search on), Source-Credit Fabrication). Each citation links to the verbatim regulator-issued source text, the tested AI question, and the recorded AI response, so the Panel's assessment is traceable end to end. For company secretaries, the citation IDs operate as a reference index: when an AI answer in the working draft matches a known Panel finding, the cited regulator text is already available as the corrective anchor. The full per-finding analysis cards, including the audience-specific impact statement, sit on the cell's detail surface for sign-off use.
This is the consolidated view of findings. Click the Citation IDs or 'see details →' on any item for the full details for each finding.
Asked which central bank chaired the CPMI working group that produced the harmonised ISO 20022 data requirements, the AI named the Federal Reserve Bank of New York. The RBA press release of 18 October 2023 confirms the Reserve Bank of Australia in that role, with Michele Bullock having served as Co-Chair of the CPMI Messaging Workstream. For a Company Secretary drafting a board briefing, regulatory submission, or director-onboarding note that references the governance lineage of this standard, the misattribution substitutes a different jurisdiction's central bank for the correct one.
The error survives casual review because the answer is specific and institutionally plausible, and only surfaces when a director, counterparty, or regulator asks for the underlying press release.
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.