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Agentic AI is only beginning to surface in U.S. finance firms' annual reports—0.4% of firms in 2024 and 1.6% in 2025—but those that mention agentic systems tend to surround them with denser governance and safety language, implying deployments are currently concentrated where governance is more mature.

Measuring agentic AI adoption and control frameworks in finance
Atta ul Mustafa, A. Aysan · Fetched March 30, 2026 · Modern Finance
semantic_scholar descriptive n/a evidence 7/10 relevance DOI Source PDF
Agentic-AI mentions in U.S. finance annual filings are nearly absent through 2023, appear in 0.4% of firm‑years in 2024 and 1.6% in 2025, and when present are associated with higher local governance/safety language, suggesting governance maturity accompanies early agentic disclosures.

Agentic artificial intelligence (AI) systems can execute actions rather than merely generate content, raising distinct governance and operational risk questions for financial institutions. This study measures how agentic AI is entering U.S. finance firms’ annual filings by treating disclosures as text-as-data. We assemble a balanced panel of 2,500 firm–year observations (500 firms per year) from 2021–2025 and implement an auditable dictionary-and-context approach that flags agentic references and then quantifies the surrounding “controls density” (governance and safety language) within the same local disclosure window. Agentic disclosures are absent in 2021–2023, appear in 2024 (0.4% of firm-years), and increase in 2025 (1.6% of firm-years), indicating a late but accelerating diffusion phase. Within the set of agentic-mention filings, autonomy evidence remains rare. However, it focuses on regions with higher control density, consistent with governance maturity serving as a prerequisite for action-taking deployments. The analysis provides a transparent measurement framework and baseline statistics for tracking the emerging shift from AI discussion to action-oriented, agentic deployments in finance.

Summary

Main Finding

Agentic AI (systems that can act, not just generate content) is just beginning to appear in U.S. financial firms’ public disclosures and remains rare through 2025, but adoption shows an accelerating pattern: agentic mentions are absent in 2021–2023, appear in 2024 (0.4% of firm‑years) and rise in 2025 (1.6% of firm‑years). When firms do disclose autonomy-positive language, it disproportionately co-occurs with dense governance/control language — supporting a “governance‑bottleneck” view that credible agentic deployment in regulated finance tends to require mature control frameworks.

Key Points

  • Agentic ≠ generative: the paper defines agentic AI as goal-directed systems integrated into workflows with delegated action/execution rights (planning, tool use, triggering downstream tasks), not merely text generation.
  • Conservative, auditable measurement: the authors use a dictionary-and-context (anchor/autonomy/controls) approach designed to minimize false positives and distinguish symbolic AI mentions from plausible operational agentic claims.
  • Diffusion pattern: no agentic disclosures 2021–23; emergence in 2024 and modest acceleration in 2025 — consistent with a late but rising diffusion phase rather than widespread current deployment.
  • Governance link: autonomy-positive cases are concentrated in passages with higher “controls density” (stronger governance/safety language), consistent with the idea that organizations only grant execution rights where control infrastructure exists.
  • Limitations acknowledged: disclosure language is strategic and imperfect; the number of autonomy-positive cases is intentionally small; results are descriptive and not causal.

Data & Methods

  • Data: Balanced panel of 500 publicly listed U.S. financial institutions observed each year 2021–2025 (2,500 firm‑year Form 10‑K filings). Firms had to file annually for the entire window; SIC codes used to define finance firms.
  • Text preprocessing: Full narrative text retained (not restricted to one item), HTML/tables/boilerplate removed; parsing to plain text to avoid spurious matches.
  • Measurement design:
    • Three domainadapted keyword dictionaries:
      • Anchor dictionary to locate candidate passages discussing agentic/system topics (e.g., “agentic”, “LLM”, “workflow automation”, “copilot”).
      • Autonomy dictionary to flag execution/orchestration/action language (e.g., “execute”, “trigger”, “orchestrate”, “function-calling”, “straight-through processing”).
      • Controls dictionary to capture governance/safeguard language (e.g., “approvals”, “audit logs”, “monitoring”, “access controls”, “model risk governance”).
    • Conservative matching rules (case-insensitive, word/phrase boundaries, plural/tense variants).
    • Anchored extraction: agentic/autonomy signals must appear in context windows identified by anchors; controls density computed as intensity of controls language within the same local disclosure window.
  • Analysis:
    • Time-series counts and rates of agentic mentions by year.
    • Within-anchor analyses evaluating co-occurrence between autonomy-positive language and controls density.
    • Robustness checks for rare events and sensitivity to dictionary choices.
  • Limitations of method: public disclosure is a noisy and strategic signal; small number of positive cases limits inference; the association between autonomy and controls is correlational.

Implications for AI Economics

  • Measurement advance: provides a transparent, replicable framework and baseline statistics for tracking agentic adoption in regulated sectors where internal deployment data are private. This helps separate hype from operational adoption in empirical work.
  • Diffusion theory refinement: adoption of agentic AI in finance appears constrained by institutional governance capacity rather than by purely technical availability — implying that models of technology diffusion should explicitly incorporate governance/organizational costs and auditability as adoption frictions.
  • Policy and regulation: regulators and supervisors should prioritize standards, tooling, and incentives for auditable controls (approvals, monitoring, logging, escalation mechanisms) because governance maturity seems to be a prerequisite for credible agentic deployment.
  • Research opportunities:
    • Extend measurement to other filings, higher-frequency disclosures, or cross‑country samples to trace diffusion beyond 2025.
    • Link disclosure signals to firm outcomes (productivity, incidents, risk events, costs, employment changes) and to supervisory actions to estimate economic impacts.
    • Combine public-disclosure measures with proprietary operational data (where available) to validate and refine measurement of action‑taking deployments.
    • Model adoption with explicit governance costs: endogenous trade‑off between efficiency gains from automation and investments in control frameworks; regulatory responses and systemic risk externalities.
  • Caution for economists: current disclosure evidence indicates emergence not ubiquity — empirical claims about widespread agentic automation in finance should account for governance constraints and the slow, institutionally mediated nature of deployment.

Assessment

Paper Typedescriptive Evidence Strengthn/a — The paper is a descriptive measurement exercise (text-as-data) that documents the prevalence and context of agentic-AI mentions in filings; it does not attempt causal inference about economic outcomes. Methods Rigormedium — Uses a balanced panel (2,500 firm‑years) and an auditable dictionary-plus-context approach that increases transparency and repeatability, but relies on rule-based text detection which is prone to false positives/negatives, potential selection bias in the 500 firms/year sample (selection criteria not specified), limited validation details (e.g., human labeling, precision/recall, robustness checks) and covers a short, early-adoption window (2021–2025). SampleBalanced panel of 2,500 U.S. finance firm–year annual filings (500 firms per year) covering 2021–2025; text-as-data analysis using a dictionary-and-local-context method to flag 'agentic' references and compute local 'controls density' (governance/safety language) around those mentions. Themesgovernance adoption org_design GeneralizabilityLimited to U.S. finance firms (not representative of other sectors or geographies)., Relies on voluntary disclosures in annual filings — firms may underreport or lag disclosures relative to deployments., Dictionary-based detection may misclassify mentions; performance depends on lexicon and context rules., Balanced sample selection (500 firms/year) may not reflect the full population (selection criteria unspecified, possible firm-size bias)., Short timeframe (early adoption period 2021–2025) may not capture later diffusion dynamics or delayed regulatory changes.

Claims (7)

ClaimDirectionConfidenceOutcomeDetails
Agentic artificial intelligence (AI) systems can execute actions rather than merely generate content. Ai Safety And Ethics positive high ability of AI systems to execute actions versus generate content
0.03
We assemble a balanced panel of 2,500 firm–year observations (500 firms per year) from 2021–2025. Other positive high dataset size and composition (firm–year observations)
n=2500
0.3
We implement an auditable dictionary-and-context approach that flags agentic references and then quantifies the surrounding 'controls density' (governance and safety language) within the same local disclosure window. Governance And Regulation positive high presence of agentic references and measured controls density in disclosure text
n=2500
0.18
Agentic disclosures are absent in 2021–2023, appear in 2024 (0.4% of firm-years), and increase in 2025 (1.6% of firm-years), indicating a late but accelerating diffusion phase. Adoption Rate positive high frequency (share) of firm–years with agentic disclosures
n=500
0.4% of firm-years (2024); 1.6% of firm-years (2025)
0.18
Within the set of agentic-mention filings, autonomy evidence remains rare. Adoption Rate negative high presence/rarity of autonomy-related evidence within agentic-mention filings
0.18
Autonomy evidence focuses on regions with higher control density, consistent with governance maturity serving as a prerequisite for action-taking deployments. Governance And Regulation positive high co-location/correlation of autonomy evidence with higher controls density in disclosures
n=2500
0.03
The analysis provides a transparent measurement framework and baseline statistics for tracking the emerging shift from AI discussion to action-oriented, agentic deployments in finance. Adoption Rate positive high availability of a measurement framework and baseline statistics for tracking agentic AI adoption in finance filings
n=2500
0.18

Notes