Annex III

Annex III is a list of purposes, not of technologies, which is why two companies running the same model can land in different tiers. It is also the practical starting point of any scoping exercise: read the eight areas against your system inventory and the high-risk question is usually answered in an afternoon. Because Article 7 lets the Commission add categories, the list is a living document — a classification decided today is a decision to revisit, not a permanent finding.

A bank runs the same gradient-boosted model for two products. Used to price a consumer loan it is Annex III point 5 — creditworthiness assessment of natural persons — and high-risk. Used to forecast the bank's own treasury liquidity it is neither, because no natural person's access to an essential service turns on the output. Same code, same team, one high-risk classification.

Reading Annex III as automatic and final. Article 6(3) allows a documented derogation where the system performs a narrow procedural task, improves a prior human activity, detects decision patterns without replacing human assessment, or does preparatory work — but the derogation never applies where the system profiles natural persons, and it must be documented and the system registered.

What are the eight Annex III categories?

Biometrics, critical infrastructure, education and vocational training, employment and worker management, access to essential private and public services including credit scoring, law enforcement, migration and border control, and administration of justice and democratic processes.

Is credit scoring high-risk under the EU AI Act?

Yes. AI used to evaluate the creditworthiness of natural persons or establish their credit score falls in Annex III, with a carve-out for systems used to detect financial fraud. Life and health insurance risk assessment and pricing is also listed.

Can Annex III change?

Yes. Article 7 empowers the Commission to add or modify use cases by delegated act where a new use poses comparable risk to health, safety or fundamental rights. Classifications should be reviewed periodically rather than decided once.