DORA and AI use cases

Annex III point 5(c): AI intended for risk assessment and pricing in relation to natural persons in life and health insurance. Article 6(3) exempts some purely preparatory tasks, but never a system that profiles natural persons. Extracting an applicant's health conditions and mapping them to the underwriting manual evaluates their health, which is profiling, so treat the system as high risk. Under the timeline as amended, the obligations for Annex III high risk systems apply from 2 December 2027, and Article 27 requires deployers of point 5(c) systems to assess the impact on fundamental rights before first use.

Complaint handling is not listed in Annex III, so internal classification and drafting for a handler who decides is minimal risk. Where the agent talks to customers to take the complaint, Article 50(1) requires telling them they are dealing with AI. Only a system that also assessed creditworthiness or priced life and health insurance (Annex III point 5(b) or 5(c)) would be high risk for that part.

Anti money laundering due diligence is not listed in Annex III, so an assistant that drafts source of wealth reports for a human decision is not high risk by default. It becomes high risk if it adds remote biometric identification of the client (Annex III point 1(a); verification that only confirms a claimed identity is excluded) or feeds an assessment of a natural person's creditworthiness, for example for lending to the client (Annex III point 5(b)). GDPR Article 22 on solely automated decisions applies if it ever refused a client on its own.

The conversational assistant falls under the Article 50 transparency duty. Biometric verification whose sole purpose is to confirm that a person is who they claim to be is excluded from the Annex III biometric category. The system becomes high risk when the same journey assesses creditworthiness or a credit score of a natural person, for example for a credit card or overdraft (Annex III point 5(b)).

Contract review and sourcing are not among the Annex III high risk uses, so an internal assistant that makes no decisions about natural persons is minimal risk (with the Article 4 AI literacy duty). If a negotiation bot chats directly with supplier staff, Article 50(1) applies and it must tell them they are dealing with an AI system, unless that is obvious from the context. Public authorities using AI in procurement should still check national public procurement rules on transparency and equal treatment of bidders.

Annex III point 5(b) makes AI systems that evaluate the creditworthiness of natural persons or establish their credit score high risk. Scoring a company is outside that point, but a sole trader is a natural person, and a model that also assesses the personal credit of owners, partners or guarantors evaluates natural persons. The tier therefore depends on who the borrower is and whose creditworthiness the model assesses.

For commercial property and casualty lines the copilot is not listed in Annex III. Used for risk assessment of natural persons in life or health insurance it falls under Annex III point 5(c) and is high risk, with risk management, data governance, logging and human oversight duties, and deployers must carry out a fundamental rights impact assessment under Article 27.

The tier depends on how the system is built. It stays minimal when the agent only executes changes approved by a person and any letter comes from a fixed template, since executing servicing changes is not listed in Annex III. It moves to limited risk when the same system talks to customers directly (the Article 50 transparency duty, described on the customer facing servicing page) or when generative AI drafts the confirmation or letter text: the provider of that generative function, the bank if it builds the system, then carries the Article 50(2) duty to mark the generated content in a machine readable way, unless the output only gets an assistive role or standard editing that does not substantially alter the input data. An AI system used to evaluate the creditworthiness of natural persons, for example to decide on a loan restructuring, is high risk under Annex III point 5(b); keep that assessment outside this agent, which only executes the decided change.

Customer due diligence on legal entities is not listed in Annex III, and an internal analyst tool usually carries no Article 50 transparency duty, so the system is usually minimal risk. The design decides the rest: biometric verification that only confirms a director is who they claim to be is excluded from Annex III point 1(a), but remote biometric identification (one to many matching) is high risk, and so is any use of the output to assess the creditworthiness of the natural persons involved (point 5(b)). GDPR applies to the personal data of owners and directors throughout. Keep biometric and credit steps in separately assessed components.

Claims handling as such is not listed in Annex III. The same system becomes high risk when it is also used for risk assessment and pricing of natural persons in life and health insurance (point 5(c)), or when it is used by or on behalf of a public authority to grant, reduce, revoke or reclaim essential public assistance benefits and services, including healthcare services (point 5(a)). Otherwise the tier is minimal, so the design and the operator decide. Decisions on claims based solely on automated processing are also subject to Article 22 of the GDPR and the UK GDPR.

Testing controls over transactions and systems is not an Annex III use. Controls that monitor and evaluate individual employees' behaviour, such as trading or access conduct, can fall under Annex III point 4(b), so the design decides the tier.

It depends on where the system runs. Classifying and routing a bank's or insurer's correspondence is not a use listed in Annex III, so it is minimal risk: the AI literacy duty of Article 4 applies, and the Article 50 duty to tell people they are dealing with AI does not, because the system does not interact with the sender. Used by or for a public authority in a benefits process covered by Annex III point 5(a), the provider can treat it as not high risk only while it performs a narrow procedural or preparatory task under Article 6(3); the provider must then document that assessment before it goes live (Article 6(4)) and register the system in the EU database (Article 49(2)). If the system evaluates eligibility for benefits or profiles the people who write in, it is high risk, so those judgements stay with people.

Assessing businesses and detecting fraud is not an Annex III use as such, and Annex III point 5(b) excludes systems used to detect financial fraud. If the system evaluates the creditworthiness of a natural person, for example a sole trader applying to accept payments, it can fall under Annex III point 5(b), which covers evaluating the creditworthiness of natural persons or establishing their credit score, and be high risk. Keep credit assessment of individuals separate or treat it as a high risk system.

Triage of phishing, endpoint, network and cloud alerts for an organization's own cyber defence is not listed in Annex III. Recital 55 of the AI Act says that components intended to be used solely for cybersecurity purposes should not qualify as safety components, so the agent does not fall under Annex III point 2 (critical infrastructure), and for this scope the tier is minimal. The design changes that when the agent triages identity, data loss prevention, insider risk or user behaviour alerts in a way that scores or monitors individual employees: monitoring and evaluating the behaviour of persons in a work relationship falls under Annex III point 4(b), so that scope needs its own high risk assessment before it goes live. The Article 50(1) duty to disclose AI interaction does not apply because it is obvious to a reasonably well informed analyst that they are working with an AI agent. An operator that lets AI act autonomously on network or operational technology controls should assess that design separately, and reading employees' emails and sign in data remains subject to data protection law.

Predicting settlement fails and handling post trade exceptions between professional market participants is not a use listed in Annex III and is not a prohibited practice under Article 5, so the tier depends on how the agent communicates. While an operator reviews and sends every message, the system is minimal risk: the messages are the firm's own correspondence and the firm as deployer owes AI literacy for staff (Article 4). Once the agent sends queries or chasers to counterparty or custodian staff itself, as the playbook recommends for routine information requests, it interacts directly with natural persons and Article 50(1) requires telling the recipients they are dealing with an AI system. In both designs the provider of the text generating system must mark its output as AI generated in a machine readable format under Article 50(2). Model risk and operational resilience controls apply on top.

A generator of synthetic tabular test data is not listed in Annex III and does not interact with people, so it is minimal risk with only the AI literacy duty of Article 4. When the system generates synthetic text, images, audio or video, such as documents or conversation transcripts, Article 50(2) requires its provider to mark the output in a machine readable format as artificially generated. When synthetic data is used to train, validate or test a high risk system, such as credit scoring, it falls under that system's data governance duties in Article 10.

Drafting client reports for human review is not listed in Annex III and is not a practice prohibited by Article 5, so the tier turns on the firm's role under Article 50. A firm that deploys a third party generator (for example a feature of its portfolio platform) for private client reports has no Article 50 duty: the Article 50(4) disclosure duty covers AI generated text published to inform the public on matters of public interest, which private client reports are not, and it lapses anyway after human review under editorial responsibility. For that firm the tier is minimal. A firm that builds the generating system or places it on the market under its own name is a provider under Article 50(2) and must mark the synthetic text in a machine readable format; drafting whole commentaries goes beyond the exemption for an assistive function for standard editing, so for that firm the tier is limited.

Answering questions and giving indicative estimates from published rules is limited risk with an Article 50(1) disclosure that the customer is talking to an AI system. If the assistant evaluates an individual's creditworthiness to decide or filter access to a loan, it falls under Annex III point 5(b) and is high risk.

Monitoring portfolios and proposing trades for human approval is not listed in Annex III and is not a prohibited practice under Article 5, so the tier turns on the firm's role under Article 50. A firm that builds or brands the rationale writer in house is a provider under Article 50(2) and must mark the generated text in a machine readable format: drafting a rationale for the drift and the proposed trades goes beyond the exemption for an assistive function for standard editing, so for that firm the tier is limited. Article 50(1) also applies once the rationale reaches the client, as this page's own implementation step allows. A firm that only deploys a third party feature for internal approver use has no Article 50 duty, and for that firm the tier is minimal. Investment conduct rules such as MiFID II suitability and best execution still apply to the resulting trades.

Summarizing research for staff is not an Annex III use and is not a practice prohibited by Article 5, so the tier turns on the firm's role under Article 50. It is minimal for a purchased internal tool with no client or public facing exposure. Article 50 transparency applies when the firm builds the generating system itself, which brings the Article 50(2) duty to mark synthetic text in a machine readable format; when the assistant is offered to clients as a chatbot, which brings the Article 50(1) duty to tell them they are interacting with AI; or when AI generated text is published to inform the public on matters of public interest, which brings the Article 50(4) disclosure duty unless the text has gone through human review or editorial control and a person holds editorial responsibility for it.

Minimal for a system level register of systems and owners with no monitoring of individual employees; it is not listed in Annex III and is the instrument deployers use to meet obligations such as the Article 26 duties for high risk systems and the Article 49 registration of Annex III systems in the EU database. Limited where the plain language assistant that staff and auditors query is not obviously an AI system to its users: under Article 50(1) its provider must then design it so people are told they are dealing with AI. Possibly high risk under Annex III point 4(b) on worker management if the discovery process monitors or evaluates the behavior of individual employees rather than staying at the level of systems and owners.

The conversational layer carries the Article 50 transparency duty. If the system assesses risk or sets prices for life or health insurance of natural persons, that part is high risk under Annex III point 5(c); pricing for property and casualty products is not listed.

Explaining products and capturing an application is limited risk with an Article 50 disclosure. If the assistant evaluates creditworthiness or filters applicants on its own assessment, it falls under Annex III point 5(b) and becomes high risk, so keep the decision in the governed credit process.

As a pure assist tool for agents it is minimal risk; the customer does not interact with the AI. It becomes high risk under Annex III point 4(b) if its data is used to monitor and evaluate individual agents' performance, and inferring agents' emotions at work is prohibited under Article 5(1)(f).

Article 50(1): people must be informed that they are interacting with an AI system, unless that is obvious from the context. Servicing existing accounts and cards is not an Annex III use. It would become high risk under Annex III point 5(b) if the agent itself evaluated the creditworthiness of a natural person, for example to decide a credit limit increase.

A customer facing assistant must tell people they are interacting with an AI system unless that is obvious (Article 50(1)). It does not evaluate creditworthiness (Annex III point 5(b)) or eligibility for public assistance benefits (point 5(a)), so it is not high risk; biometric verification whose sole purpose is to confirm identity is excluded from Annex III point 1(a).

A customer facing assistant must tell people they are interacting with an AI system (Article 50(1)). It triages and opens cases but does not evaluate creditworthiness (Annex III point 5(b), which in any case excludes systems used to detect financial fraud) or decide access to an essential service, so it is not high risk under Annex III.

An AI system that interacts directly with people must be designed so that they know they are dealing with AI, unless that is obvious from the context (Article 50(1)). It is not high risk under Annex III as long as it does not evaluate eligibility for essential public assistance benefits and services (point 5(a)), creditworthiness (point 5(b)), risk and pricing for life and health insurance (point 5(c)) or emergency calls (point 5(d)). This holds only if emotion or vulnerability signals are inferred from what the customer says (text or transcript content), not from voice or other biometric features; an agent that infers emotion from a caller's voice is an emotion recognition system (Article 3(39)), which is high risk under Annex III point 1(c) and triggers the deployer disclosure duty in Article 50(3).

Confirming flagged transactions with cardholders is not listed in Annex III, and point 5(b) expressly excludes AI used to detect financial fraud from the creditworthiness category, so the system is not high risk. An agent that messages or calls customers must tell them they are dealing with AI under Article 50(1), and synthetic voice output must be marked as AI generated under Article 50(2).

A customer facing assistant must be designed so that people know they are interacting with AI (Article 50(1), applicable from 2 August 2026). It is not high risk as long as it does not carry out risk assessment and pricing in relation to natural persons in life and health insurance (Annex III point 5(c)).

Article 50(1) requires an assistant that talks with people to make clear they are interacting with AI, unless that is obvious from the context. It is not listed in Annex III. The agent does allocate work, but it routes tickets to resolver and assignment groups based on the content of the request, not to individual workers based on their behaviour or personal traits or characteristics, so Annex III point 4(b) does not apply. It also does not decide on recruitment, promotion, credit or access to essential services. Any use that assigns work to individual analysts, or monitors and evaluates them from their behaviour or performance (including through the agent's logs), would need its own assessment.

A customer facing agent must make clear that people are dealing with AI, unless that is obvious from the context (Article 50). Initiating payments within a customer's mandate is not listed in Annex III. It becomes high risk if the same agent evaluates creditworthiness, for example by deciding on a buy now pay later or credit line at checkout (Annex III point 5(b)).

A customer facing agent must disclose that it is AI (Article 50(1)). It stays out of Annex III as long as eligibility for credit offers is decided upstream by the bank's own, separately governed credit processes; if the agent itself assessed creditworthiness it would be high risk under point 5(b).

A chatbot that interacts with people at client companies must disclose that it is AI (Article 50). It does not evaluate creditworthiness or decide on access to an essential service (Annex III point 5), so it is not high risk.

A chatbot that interacts with developers must disclose that it is AI (Article 50). Code generation for integration is not listed in Annex III.

Forecasting a company's cash flows is not listed in Annex III and makes no decision about a natural person, so the forecasting model itself carries no obligations beyond AI literacy (Article 4). The conversational layer interacts directly with treasury staff, so under Article 50(1) they must be informed that they are dealing with an AI system unless that is obvious from the context. Without a conversational layer the use case is minimal risk.

Article 50(1) requires that people who interact directly with an AI system are informed of it, unless this is obvious from the context, as it usually is for an internal assistant. The system would be high risk only if it were intended for an Annex III purpose, such as assessing the creditworthiness of natural persons (point 5(b)) or making decisions on or evaluating workers (point 4(b)).

Not an Article 5 practice and not listed in Annex III: the system prepares filings for authorities and makes no decision on the credit, insurance, employment or access to services of a natural person. It is an internal tool whose users know they are working with AI, and drafted text that ends up in public disclosures passes human review under a named person's editorial responsibility, which takes it outside the Article 50(4) deployer disclosure duty. The system still drafts variance commentary and plain language explanations of validation failures from underlying data, rather than lightly editing existing text, so the assistive function for standard editing exception does not fit. The bank that builds or operates the system is then the provider and carries the Article 50(2) duty to mark that generated text in a machine readable way as artificially generated, which has applied since 2 August 2026. The AI literacy duty of Article 4 also applies.

Article 50(1) requires that people who interact directly with an AI system are informed of it, unless this is obvious from the context, as it usually is for an internal assistant labelled as AI; Article 50(2) requires providers of systems that generate text to mark the output as AI generated in a machine readable way. Helping advisors find information is not an Annex III use and not a prohibited practice under Article 5. It would become high risk only if the system were used to evaluate the creditworthiness of clients (point 5(b)) or to evaluate or make decisions about advisors (point 4(b)). If the assistant were opened to clients, they would have to be told they are dealing with AI.

Operational setup of accounts and entitlements for corporate clients is not listed in Annex III and makes no decision about a natural person's access to a service or creditworthiness. The agent chases documents directly with client staff, so Article 50(1) applies: the provider must design the system so that they are informed that they are interacting with an AI system, unless that is obvious from the context. A purely internal version without client contact would be minimal risk.

An internal tool that monitors and classifies regulatory publications for staff makes no decisions about natural persons, so it is not listed in Annex III and is not a prohibited practice under Article 5. Staff know they are using an AI tool and its summaries are not published to the public, so the Article 50 duties to inform users and to disclose published generated text add little for the deploying organization. Article 50(2) still requires the provider of a system that generates text to mark its output, in a machine readable format, as AI generated: usually the vendor, but an organization that builds its own summariser can itself be that provider, which is what puts this use case at the limited tier rather than minimal. Beyond this and AI literacy (Article 4), no specific obligations apply. General model risk and third party rules still apply.

Annex III point 5(b) expressly excludes AI systems used to detect financial fraud from the high risk creditworthiness category, so the scoring is not high risk. The conversational part must disclose that it is AI under Article 50(1). If a voice component infers the customer's emotions from their voice, it becomes an emotion recognition system under Annex III point 1(c), which is high risk and needs the Article 50(3) notice, so keep coaching detection to what is said rather than to biometric signals.

Article 50(1) requires providers to design AI systems that interact directly with people so that those people are informed they are dealing with AI, unless this is obvious from the context, as it usually is for an internal assistant. An analytics assistant that makes no decisions about people is not a prohibited practice under Article 5 and is not listed in Annex III. It would be high risk only if it were intended for an Annex III purpose, such as assessing the creditworthiness of natural persons (point 5(b)).

Internal triage of fraud alerts is not listed in Annex III, and point 5(b) explicitly excludes fraud detection from the high risk creditworthiness category. Article 50(1) covers any system that interacts directly with people, analysts included, but it does not apply where the use of AI is obvious to a reasonably well informed user, as it is in an internal analyst tool; the marking duties for generated content in Article 50(2) sit with the provider. Reassess if its output feeds credit decisions. Decisions that affect customers remain subject to GDPR and consumer protection rules.

A coding assistant used by developers is not a prohibited practice under Article 5 and is not listed in Annex III. Developers know they are working with an AI tool, so the Article 50 disclosure duty has no practical effect for the deploying organization, and the marking of generated content under Article 50(2) falls on the tool's provider. What remains is AI literacy (Article 4). Using an AI system to monitor or evaluate individual developers' performance would fall under Annex III point 4(b), and the software the assistant helps build may itself fall under the Act.

Bankers interact with the copilot directly, but Article 50(1) does not bite here: it requires telling people they are dealing with an AI system unless that is obvious to a reasonably well informed person, and an internal tool that is openly presented and labelled as an AI assistant meets that bar by design. The copilot never interacts with the client. Article 50(2) marking of generated text falls on the provider of the system, including a bank that builds it in house, but the copilot turns a banker's own notes into a call report, an assistive function for standard editing of the banker's input that does not substantially alter it, so the Article 50(2) exception applies and no machine readable marking is required. It is not an Annex III use: credit context about corporate clients is not the creditworthiness assessment of natural persons in Annex III point 5(b), so it falls outside the high risk tier. If a deployment starts to score individuals for credit, the tier changes. AI literacy duties under Article 4 still apply. If meeting capture is used, recording and transcription rules under data protection law apply separately.

Drafting internal reports for a human investigator is not listed in Annex III (the law enforcement uses in point 6 cover systems used by or for law enforcement authorities, not a bank's own reporting), and the text is not published to inform the public, so the deployer disclosure duty for generated text in Article 50(4) does not apply. Confidentiality rules for suspicious activity reports and GDPR apply in full.

Checking trade documents for compliance with credit terms is not listed in Annex III and does not decide about natural persons. AI literacy duties under Article 4 apply, and the process falls under the bank's operational resilience and model governance.

AML transaction monitoring is not listed in Annex III; point 5(b) covers creditworthiness and credit scoring and excludes systems used to detect financial fraud. The Article 5(1)(d) ban on predicting criminal offences from profiling alone does not apply to systems that support a human assessment already based on objective and verifiable facts linked to criminal activity, which is how alert triage should be designed. A decision to restrict an account taken solely by automated means would fall under GDPR Article 22 and national AML law, so consequential decisions need human review.

Dispute processing between issuers, acquirers and merchants is not listed in Annex III. It is not an evaluation of creditworthiness or credit scoring under Annex III point 5(b), and because cardholders do not interact with the system directly, the Article 50(1) transparency duty for AI that talks to people does not apply. Article 50(2) marking of generated text is a duty of the provider of the AI system that generates it, which includes an institution that builds its own dispute drafting agent and puts it into service under its own name. A drafted rebuttal built from attached case evidence performs an assistive function for standard editing of that evidence and does not substantially alter the underlying input, so it falls under the Article 50(2) exception and does not need machine readable marking. With that point checked, the tier stays minimal. A customer facing intake agent is assessed separately.

Intake and triage for commercial insurance is not listed in Annex III, which covers risk assessment and pricing of natural persons in life and health insurance. It moves up to high risk only if the same pipeline is used to assess or price life or health cover for individuals.

An internal tool that supports engineers on IT incidents; it is not a use listed in Annex III and makes no decisions about people. Annex III point 2 covers AI used as a safety component in the management and operation of critical digital infrastructure, and recital 55 limits safety components to systems that directly protect the physical integrity of that infrastructure or the health and safety of persons and property. A triage copilot that proposes causes and fixes to engineers does not normally do that, but operators of critical digital infrastructure (cloud, data centers, telecom networks) should confirm this for their own design.

Matching entries between internal financial records is not a use listed in Annex III and is not a practice prohibited by Article 5. Operators knowingly use an internal AI tool, so no Article 50(1) disclosure is needed. If a generative model drafts the explanations or journals, the provider of that system may have to mark its output as AI generated under Article 50(2). The AI literacy duty of Article 4 applies to the bank as deployer.

Tools that analyze, document and translate code are not prohibited practices under Article 5 and are not listed in Annex III, so no high risk obligations apply to the tooling. Engineers and analysts know they are working with an AI tool, including when they query the documentation through a chat assistant, so the Article 50 disclosure duty has no practical effect for the deploying organization. What remains is AI literacy for the staff who use it (Article 4). If the system being modernized is itself an AI system in an Annex III area (for example creditworthiness assessment, point 5(b)), its new version still has to meet the high risk requirements.

Detecting mule accounts is fraud and AML detection by a private firm, which Annex III does not list; point 5(b) explicitly excludes systems used to detect financial fraud from the credit scoring category. Restricting an account based solely on an automated score can be a decision with similarly significant effects under GDPR Article 22, so keep a human decision and a route to challenge.

Handling payment exceptions is not a use listed in Annex III and is not a prohibited practice under Article 5. If the agent interacts directly with customers, for example in a chat about the case, Article 50(1) requires that they are told they are interacting with an AI system.

Sanctions screening by banks and payment firms is not listed in Annex III: point 5 covers credit scoring and life and health insurance pricing, and point 6 covers AI used by or on behalf of law enforcement authorities. It is not a prohibited practice under Article 5, and as an internal tool it carries no Article 50 transparency duty. It still processes personal data at scale, so GDPR applies, and decisions that block a payment or freeze assets remain human decisions.

Drafting and triaging code fixes for an organization's own software is not an Annex III use, and developers, not the public, interact with the system. The software being fixed remains subject to its own security and resilience rules, whoever wrote the fix.

Drafting regulatory correspondence for human approval is not an Annex III use. The main risks are confidentiality and accuracy, which are handled by supervisory information rules, data protection law and internal controls.

Processing supplier invoices is not an Annex III use case, is not a practice prohibited by Article 5 and does not involve decisions about natural persons, so it is minimal risk and the AI literacy duty of Article 4 applies. Approvers who ask questions in chat use an internal tool they know is AI; if that is not obvious to the people using it, the provider must also inform them that they are interacting with an AI system (Article 50(1)).

Assessing organizations as vendors is not an Annex III use. If assessments score individual natural persons, such as sole traders, check the design against Annex III and data protection rules. The EU AI Act also shapes what to ask AI vendors, since providers of high risk systems carry specific obligations.

Transcribing and summarizing meetings for an employee is not a use listed in Annex III, and the advisor reviews every note before it is filed or sent. The tier would change if the tool inferred emotions: emotion recognition is high risk under Annex III point 1(c), and inferring the emotions of employees at work is prohibited under Article 5(1)(f). Both stay out of scope.

Financial crime screening of trade transactions is not listed in Annex III. It still processes personal data of individual parties, so GDPR applies, and supervisors expect it to be governed like any financial crime model.

An internal assistant that drafts requirements artifacts and test cases for engineers is not listed in Annex III and does not interact with the public, so no specific obligations apply beyond AI literacy (Article 4). The system under test may itself fall under the Act.

An internal drafting and analysis assistant for auditors that makes no decisions about natural persons. It would need reassessment if used to evaluate individual employees' behaviour or performance, which falls under Annex III point 4(b).

Annex III point 5(b) lists creditworthiness assessment and credit scoring of natural persons as high risk but explicitly excludes AI systems used for the purpose of detecting financial fraud, and payment fraud scoring is not otherwise listed in Annex III or prohibited by Article 5. Behavioural biometrics used only to confirm that customers are who they claim to be fall under the biometric verification exclusion in Annex III point 1(a). The model does not interact with people, so Article 50 does not apply. GDPR Article 22 can still apply to solely automated declines with significant effects on customers.