EU AI Act compliance for credit scoring & lending AI

AI used to evaluate creditworthiness or set credit scores for individuals is high-risk under the EU AI Act — outside of fraud detection. The obligations are extensive and documentation-heavy.

Why it is in scope

Annex III(5)(b) lists creditworthiness assessment and credit scoring of natural persons as high-risk, given the impact on access to essential financial services.

Key obligations

• Risk management system (Article 9)
• Data governance and bias mitigation on training data (Article 10)
• Annex IV technical documentation (Article 11)
• Accuracy, robustness, and cybersecurity (Article 15)
• Human oversight (Article 14)
• Conformity assessment and EU database registration (Articles 43, 49)