Classified examples · Credit, fraud and insurance · Po polsku
AI scores consumers' creditworthiness
High-risk (Annex III)Deployer
A lender or a shop offering instalments uses an AI model to decide whether and on what terms to grant credit to individuals.
How we classify it
- Annex III point 5(b) lists AI intended to evaluate the creditworthiness of natural persons or establish their credit score: high-risk.
- Deployers of these systems must also carry out a fundamental rights impact assessment before first use (Article 27).
- Result: high-risk, with deployer duties and the impact assessment from 2 December 2027; GDPR and consumer credit law apply now.
What applies now
- GDPR Article 22 safeguards for automated credit decisions: human intervention, the right to contest
- Explainable reasons for refusals under consumer credit rules
- Ask the model vendor about documentation, testing and bias
What would change the answer
- From 2 December 2027: fundamental rights impact assessment, human oversight, logs, informing applicants, right to an explanation (Articles 26, 27, 86)
Evidence to keep
- Classification record
- Fundamental rights impact assessment
- Vendor documentation
- Decision logs
In the AI Compliance Kit: 04Risk Classification Procedure · 09AI Impact Assessment Template · 07Vendor Due Diligence Questionnaire.
Dates and sources
- High-risk obligations for stand-alone systems (Annex III): 2 December 2027
Legal basis: AI Act art. 26, 27, 86, Annex III point 5(b); GDPR art. 22.
Similar examples
- AI flags suspicious payments and fraud Minimal risk
- AI prices life or health insurance for individuals High-risk (Annex III)