research / regulated-evals

A regulation-anchored Trustworthy-AI Scorecard for frontier models in regulated finance

Abstract We ask a narrow, falsifiable question: is any current language model ready, out of the box, to behave safely in regulated finance? We grade ten models (four frontier-closed: Claude Opus 5, Claude Sonnet 5, GPT-5, Gemini 2.5 Pro; three frontier-open: DeepSeek-V3.1, Mistral-Large, Qwen-2.5-72B; and three small open-weight baselines, API-served) across two deployment profiles, against preregistered floor/target bars derived from the EU AI Act, FINMA guidance, DORA, the revised Swiss FADP and banking-secrecy law. Judgment cases (route-vs-advise, fabrication-vs-illustration, prompt-injection) are scored by a cross-family LLM panel that we first calibrate against a blind human rater. Every verdict re-derives from frozen transcripts at zero model cost.

Key result

Loading the verdicts…

1 The scorecard

Each cell is one requirement for one model, on one deployment profile, scored absolutely against its preregistered bar, never on a curve. A single Critical failure means Not-ready; it cannot be averaged away. Click any cell to read the actual scenarios and the model's own responses behind the verdict.

profile

Figure 1. Model × requirement readiness on the frozen finance-v2 corpus. Cell value is the pass-rate; colour is the absolute verdict against the preregistered floor/target.

2 Risk interpretation

A metric alone is not a decision. Each open finding above is read through a versioned, categorical decision table: verdict and criticality plus whether the cited obligation binds the reference deployer today, into a severity a deployment conversation can use. No numeric weighting, no single blended number; the per-card summary is the maximum open severity, never a count or an average. Evidence confidence never changes a severity; it says how much to trust the measurement behind it (an asterisk marks provisional findings).

Table 1. Highest open severity per model and profile, with the weakest evidence tier among the findings at that level. Methodology: spine/interpretation.md in the repo; severity vocabulary: blocker · material · advisory · note.

3 Per-requirement detail

Pass-rate per model for one requirement, against the preregistered bars. The shaded bands mark the fail / partial / pass zones; the dashed lines are the floor and target.

requirement

Figure 2. Per-model pass-rate for the selected requirement.

4 Why trust the grader?

Judgment cases are graded by an LLM panel, but only because it first cleared a preregistered bar against a human rater on a 150-item blind pack. Two independent humans agree with each other far more than either agrees with the old rule grader: the rule was the outlier, which is the empirical case for the panel.

Figure 3. Inter-rater reliability (Krippendorff's α).

Per-family deployment gate

Panel-vs-human α per judgment family against the preregistered bands. α is prevalence-fragile where one class is rare; read raw agreement and fail-recall alongside it.

Table 2. Preregistered per-family gate: α ≥ 0.80 publish · 0.667–0.80 tentative · < 0.667 do-not-deploy.

5 Regulation cross-walk

Every requirement is anchored to named regulation and gates differently by deployment profile: an anonymous public bot must refuse all personal data; an authenticated assistant may serve the logged-in user but never another.

Table 3. Requirement → model-behavior test → per-profile criticality → regulatory anchor.

6 How it works

regulation-anchored

Each requirement carries an industry-specific regulatory anchor; bars come from the law, not from a leaderboard curve.

preregistered

Floor/target are fixed before a model is run, never tuned to a result; each card stamps its thresholds, dataset version and run date.

reproducible

Every verdict re-derives from a frozen transcript at zero model cost (make repro); judge majorities re-derive from cached per-judge votes, offline.

honest

No single 0-100 score. Readiness is a structured signal, not approval; a ✗ sizes the system wrap a deployer must build; it is not "a bad model".