AI Act FAQ

AI in Credit Scoring: Frequently Asked Questions

5 questions answered with specific EU AI Act article references. 98 days until the August 2, 2026 enforcement deadline.

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Is credit scoring AI high-risk?

Yes. AI systems used for creditworthiness assessment and credit scoring are explicitly listed as high-risk under Annex III category 5(b).

What obligations apply?

Full high-risk compliance: risk management (Article 9), data governance (Article 10), technical documentation (Article 11), transparency to applicants, human oversight for final decisions, and non-discrimination testing.

Must credit decisions be explainable?

The AI Act requires transparency (Article 13) and human oversight (Article 14). Combined with GDPR Article 22 (right to explanation of automated decisions), credit scoring AI must provide meaningful explanations.

Does GDPR also apply?

Yes. Credit scoring involves personal data processing. Both GDPR and AI Act apply simultaneously. DPIA under GDPR and conformity assessment under AI Act are both required.

What about open banking AI?

AI systems using open banking data for creditworthiness fall under Annex III 5(b). Additional DORA requirements apply if the provider is a financial entity.

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