Credit scoring AI is high-risk. Insurance pricing AI is high-risk. Are you ready?
Financial services AI falls under Annex III Domain 5 — access to essential services. KlarvoEngine classifies your systems against both the AI Act and sector-specific regulation (MiFID II, DORA, CRD).
Classify your financial AI systemsHow KlarvoEngine classifies financial AI
| AI System | Classification |
|---|---|
| Credit Scoring | HIGH-RISK |
| Insurance Risk Pricing | HIGH-RISK |
| Fraud Detection | MINIMAL RISK |
| KYC/Onboarding | HIGH-RISK |
| Robo-Advisory | LIMITED RISK |
| Algorithmic Trading | CASE-BY-CASE |
| AML Screening | MINIMAL RISK |
| Debt Collection Scoring | HIGH-RISK |
| Customer Chatbot | LIMITED RISK |
The AI Act doesn't exist in isolation
KlarvoEngine's financial services framework maps obligations across:
MiFID II
Suitability requirements for AI-driven investment advice. The AI Act adds transparency and oversight requirements on top.
DORA
Digital Operational Resilience Act requires resilience testing for critical ICT — including AI systems. Applies from January 2025.
CRD IV / Basel
Model risk management requirements for AI credit models. Existing validation requirements plus new AI Act obligations.
Consumer Credit Directive
Specific explainability requirements for credit decisions that may exceed AI Act minimums.
Your obligations as a deployer
Human Oversight (Article 14)
Credit decisions must have meaningful human review. The person must understand the system and have authority to override.
FRIA (Article 27)
Mandatory for credit scoring and insurance pricing AI. KlarvoEngine pre-fills from classification data.
Logging (Article 12)
Retain logs for at least 6 months. Credit decisions require full traceability for supervisory review.
Transparency to Applicants
Inform individuals when AI influences credit or insurance decisions. GDPR Article 22 also applies.
Non-Discrimination Monitoring
Monitor for bias across protected characteristics. Financial regulators expect ongoing testing.
Frequently Asked Questions
Is credit scoring AI high-risk under the EU AI Act?
Yes. AI systems used to evaluate creditworthiness are explicitly listed in Annex III Domain 5(b) as high-risk, requiring full compliance with deployer obligations under Article 26.
How does DORA interact with the EU AI Act?
DORA and the AI Act are complementary. DORA focuses on ICT risk management and operational resilience while the AI Act addresses AI-specific risks. Financial services firms need to comply with both.
What about robo-advisors?
Robo-advisors are typically limited risk under the AI Act but fall under MiFID II suitability requirements. KlarvoEngine maps obligations across both frameworks.
When do these obligations apply?
Most obligations apply from 2 August 2026, but prohibited practices and AI literacy requirements applied from 2 February 2025. Credit scoring and insurance AI should prepare now.
Prepare your financial services for compliance.
KlarvoEngine classifies credit scoring, insurance, and financial AI with article-level precision. Free to start.