Financial services AI — from credit scoring to fraud detection — faces high-risk classification under the EU AI Act. Banks and insurers must also navigate dual compliance with DORA, MiFID II, and Solvency II.
Financial services is explicitly targeted by the EU AI Act. Credit scoring, insurance underwriting, and anti-money laundering systems are listed as high-risk in Annex III, Category 5. The sector also faces unique dual compliance challenges: the Digital Operational Resilience Act (DORA), MiFID II, PSD2, and national financial regulations all intersect with AI Act obligations. Financial institutions using AI for automated decision-making about individuals face the strictest scrutiny.
AI systems that assess creditworthiness, determine loan eligibility, or set credit limits for individuals.
Real-time transaction monitoring, anomaly detection, and fraud prevention systems.
Anti-money laundering screening, know-your-customer verification, and sanctions checking systems.
AI-driven risk assessment, premium calculation, and claims processing for insurance products.
Automated trading strategies, market making, and portfolio optimization systems.
AI chatbots for banking inquiries, account support, and financial product recommendations.
Financial AI systems are primarily classified under Annex III, Category 5 (access to essential private services). Credit scoring and insurance underwriting AI that make or materially influence decisions about individuals' access to financial services face full high-risk obligations. The overlap with DORA means financial institutions must also ensure AI systems meet digital operational resilience requirements, including ICT risk management frameworks and incident reporting.
Inventory AI in lending, insurance, trading, compliance, and customer service. Include vendor-provided AI embedded in financial platforms.
Map AI Act requirements against DORA ICT risk management, MiFID II algorithmic trading rules, and other financial regulations to avoid duplication.
For credit scoring and insurance AI, document how you test for discriminatory outcomes across protected characteristics.
Ensure AI-assisted financial decisions can be explained to affected individuals. This serves both AI Act transparency and existing financial regulation requirements.
Build on existing model risk management frameworks to incorporate AI Act requirements for ongoing monitoring, validation, and documentation.
In-depth guide covering DORA overlap, credit scoring obligations, and MiFID II alignment.
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