Is Credit Scoring High-Risk Under the EU AI Act? (Annex III)
When AI decides whether you get a loan, an insurance policy, a benefit or an ambulance, the stakes are existential. Annex III point 5 makes access to essential private and public services high risk.
What Annex III(5) covers
- Eligibility for public assistance benefits and services
- Creditworthiness and credit scoring (except fraud detection)
- Risk assessment and pricing in life and health insurance
- Emergency-call triage and dispatch
Who’s affected
Banks and lenders, insurers, fintechs, public benefits agencies, and emergency services — plus the AI vendors serving them.
Why it’s high risk
High risk under Annex III(5). Credit scoring is expressly named — the only carve-out is AI used to detect financial fraud. Deployers owe affected people transparency about automated decisions that affect them.
Obligations to prepare for
FAQ
Is AI credit scoring always high-risk?
Yes, with one exception: AI used to detect financial fraud is carved out. Evaluating creditworthiness or establishing a credit score is high-risk under Annex III(5).
Is AI insurance pricing high-risk?
Risk assessment and pricing in life and health insurance is expressly high-risk under Annex III(5). Other insurance lines are judged on their own facts.
Being high-risk sets the obligations; your role decides who owns them. See provider vs deployer duties · sector detail: Fintech & Banking, Insurance.
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