Agents gather financials, spread accounts and draft credit papers; they do not approve credit. A credit team's approver authority matrix links each decision an AI agent prepares to the analyst, credit officer or committee that may approve it, covering limits, policy overrides, covenant waivers and rating changes within written authority.
How do agents fit into credit authority?
Credit authority is already layered: analysts recommend, credit officers approve up to a limit, a committee approves above it. Agents enter at the bottom of that ladder, not beside it. A credit agent can read filed accounts and bureau data at depth 1, spread financials and draft a credit paper at depth 2, and flag covenant breaches from management accounts. It does not approve credit.
That is a deliberate choice, and a defensible one. A credit decision commits the lender to risk for years, rests on judgement about management and markets that no source captures fully, and in some cases affects individuals: under the EU AI Act, creditworthiness assessment and credit scoring of natural persons are high-risk uses. Even for business lending, where the borrower is a sole trader or the guarantor is a person, the same care applies. The matrix records exactly where the agent's work ends and the approver's begins. The wider idea is set out in what an authority matrix is.
How do you fill it in?
- Copy your current credit authority schedule. Its limits do not change because an agent is involved.
- Add a column for the agent's part and depth in each decision.
- Add a column for the evidence the approver must check personally, rather than accept from the agent's paper.
- Add the certificate required, if approval rights are tied to certification.
- Keep the committee row: some decisions should never be delegated to an individual, whatever the evidence.
The template
| Credit decision | Agent's part and depth | Approver | Limit | Must check personally | Second approver or committee | Certificate |
|---|---|---|---|---|---|---|
| New credit limit | ||||||
| Increase to existing limit | ||||||
| Annual review, no change | ||||||
| Policy override | ||||||
| Covenant waiver or amendment | ||||||
| Risk rating change | ||||||
| Move to watchlist | ||||||
| Security release |
A worked example
A hypothetical commercial lender with eight credit analysts, four credit officers, a head of credit and a credit committee. Values are illustrative.
| Decision | Agent's part | Approver | Limit | Must check personally | Second approver or committee | Certificate |
|---|---|---|---|---|---|---|
| New limit | Spreads accounts, drafts paper (2) | Credit officer | 500,000 | Management accounts against filed accounts | Above 500,000, head of credit; above 2,000,000, committee | Operator |
| Limit increase | Drafts paper (2) | Credit officer | 250,000 increase | Recent trading | Above that, head of credit | Operator |
| Annual review | Drafts review (2) | Credit analyst | No change to limit or rating | Covenant compliance | None | Operator |
| Policy override | Summarises case (1) | Head of credit | All | Rationale | Always, committee | Operator |
| Covenant waiver | Drafts options (2) | Head of credit | All | Cause of breach | Always, second senior credit officer | Operator |
| Rating change | Proposes rating (2) | Credit officer | One notch | Drivers | Two or more notches, head of credit | Operator |
| Watchlist | Flags triggers (1) | Credit officer | All | Trigger evidence | None | Operator |
| Security release | Drafts release (2) | Head of credit | All | Remaining exposure | Always, legal | Operator |
Policy overrides sit at depth 1. The agent may summarise the case for the committee, but it does not draft the argument for the override. That keeps the persuasive case in a person's words, where the committee can test it.
The "must check personally" column carries the most weight. A credit officer approving a new limit must compare management accounts, often supplied by the borrower and therefore declared, with filed accounts or audited figures, which are signed. The agent will spread whatever it is given. The officer's job is to notice when the two disagree.
Credit control works downstream of this matrix; see the approver authority matrix for the credit control team. System access to bureau and filing sources is approved under the approver authority matrix for the IT team. Detailed thresholds belong in the approver rule for the credit team, with downstream limits in the approver rule for the credit control team. Credit officers can evidence their review skill with Pryme Intelligence Academy's Operator certificate, valid 12 months. The broader skills map is AI agent skills by role.
Questions people ask
Could an agent ever approve small credit limits?
Some lenders may consider depth 3 for very small, policy-standard limits once the agent has earned that depth on their own past decisions. Many keep all credit approvals with people, especially where individuals are affected.
Does using an agent change the committee's role?
No. The committee still approves the largest and most unusual decisions. It may want to see which parts of a paper the agent drafted, so it can test them.
What if the agent's spreading certificate lapses?
Analysts spread accounts themselves until the agent is recertified. Approvals are unaffected, but papers take longer, so plan around the lapse date.