Which AI use cases in banking are high risk under the EU AI Act?

Annex III point 5(b): AI systems intended to evaluate the creditworthiness of natural persons or establish their credit score are high risk, except systems used to detect financial fraud. Providers need risk management, data governance, logging and human oversight. Deployers must carry out a fundamental rights impact assessment before use (Article 27), and affected persons have a right to an explanation of individual decisions from the deployer (Article 86).

Scoring individual agents' interactions to monitor and evaluate their performance and behavior falls under Annex III point 4(b), employment and worker management. The Article 6(3) exception does not apply where the system profiles natural persons. Inferring agents' emotions is prohibited under Article 5(1)(f), except for medical or safety reasons. Inferring customers' emotions from their voice is emotion recognition on biometric data: high risk under Annex III point 1(c), and Article 50(3) requires informing the people exposed to it. Analytics that only aggregate interaction themes without evaluating individuals can fall outside the high risk category.

Annex III point 5(b) lists AI systems used to evaluate the creditworthiness of natural persons or establish their credit score. A system that approves, refers or conditions a mortgage for a consumer falls under it, with risk management, data governance, logging, human oversight and conformity assessment obligations.

Annex III point 5(b): AI systems intended to evaluate the creditworthiness of natural persons or establish their credit score are high risk, and a real time BNPL underwriting model is squarely this use, since it is the system making the credit decision rather than a supporting tool. Providers need risk management, data governance, logging and human oversight; deployers must run a fundamental rights impact assessment (Article 27), and consumers have a right to an explanation of an individual decision (Article 86).

The conversational assistant carries the Article 50 transparency duty: customers must be told they are interacting with an AI system. The system becomes high risk if it is used to evaluate the creditworthiness of natural persons or establish their credit score (Annex III point 5(b)). Article 5(1)(b) prohibits AI that exploits vulnerabilities due to a person's specific social or economic situation to materially distort their behavior in a way that causes, or is reasonably likely to cause, significant harm.

Classification and indexing of documents for a person to review may fall under the Article 6(3) derogation for narrow procedural tasks, if the provider documents that assessment. That derogation does not apply once the system profiles a natural person: calculating a named borrower's qualifying income from their pay stubs and bank statements evaluates that person's economic situation, which is profiling under GDPR Article 4(4). A system intended to calculate qualifying income for the credit decision is high risk under Annex III point 5(b), evaluating the creditworthiness of natural persons, whether or not a person reviews its output. Human oversight of that output is a separate obligation under Article 14, not a way to take the system out of the high risk category.

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).

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.

Annex III point 5(b) makes AI used to evaluate the creditworthiness of natural persons high risk. Credit analysis of companies is outside that point, but the tier can change when the same system evaluates the creditworthiness of natural persons, such as sole traders, partners who are personally liable or personal guarantors. Design the scope explicitly and document it.

Keeping customer due diligence files current is not listed in Annex III, so a back office system that assembles reviews for an analyst to decide is usually minimal risk. The design decides the rest: a conversational agent that asks customers for missing information must tell them they are interacting with an AI system (Article 50(1)); biometric verification that only confirms a person is who they claim to be is excluded from Annex III point 1(a), while remote biometric identification is high risk; and Article 5(1)(d) prohibits assessing the risk that a person will commit a criminal offense based solely on profiling, so behavioral triggers should open a review for a human rather than score the customer. GDPR applies to the collection and retention of KYC data, including Article 22 if an automated refresh leads to a decision with legal or similarly significant effect, such as closing an account.

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.

Annex III point 5(b) excludes AI used to detect financial fraud from the high risk credit scoring category, but a system that in effect decides on creditworthiness is high risk, and remote biometric identification is high risk under point 1(a), which excludes one to one biometric verification. When a public authority uses the model on claims for public benefits, point 5(a) can apply, because it covers AI used to grant, reduce, revoke or reclaim benefits and has no fraud exception. Keep fraud detection separate from the credit or eligibility decision and use biometrics only for one to one verification.

Verifying documents and third party data for a person or system to use is a narrow procedural task under Article 6(3) when the credit decision itself is made separately. That derogation does not save the system if it profiles natural persons: Article 6(3)'s last subparagraph makes an Annex III system high risk regardless of the procedural task exception when it does. Calculating an applicant's income and checking it against what people in that job are normally paid, which is how Informed.IQ describes its Ally Financial deployment, evaluates a person's economic situation and is profiling under GDPR Article 4(4), so that step will usually be high risk unless it is strictly limited to checking document authenticity rather than calculating or assessing income. Annex III point 5(b) separately excludes AI used to detect financial fraud from the high risk credit scoring category, which covers this use case's fraud screening step on its own. The tier also changes if the verification result automatically decides or materially narrows a consumer's access to auto financing, since retail auto loan applicants are natural persons: that use falls under Annex III point 5(b) as evaluating creditworthiness directly.

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.

Monitoring the credit of companies is not listed in Annex III. Where the same system evaluates the creditworthiness of natural persons, such as sole traders or personal guarantors, it falls under Annex III point 5(b) and is high risk; because that evaluation profiles natural persons, the Article 6(3) exemption does not apply.

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.

Ranking offers is generally minimal risk and the conversational part carries the Article 50 transparency duty. Using AI to evaluate creditworthiness for a credit offer is high risk (Annex III point 5(b)), and Article 5 prohibits techniques that exploit vulnerabilities due to a person's social or economic situation to distort their behavior in a harmful way.

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 onboarding process assesses creditworthiness or a credit score of a natural person, for example for a credit card or overdraft (Annex III point 5(b)).

Answering policy questions and starting routine requests is limited risk, with the Article 50 duty to disclose AI. It becomes high risk under Annex III point 4 if it is used to make or support decisions on recruitment, promotion, termination, allocating tasks based on individual behavior or personal traits, or the monitoring and evaluation of workers; an employer deploying it then must also inform workers' representatives and the affected workers before use (Article 26(7)). Sensitive topic detection should work on what the employee writes: inferring emotions of people in the workplace from biometric data such as voice or facial expressions is prohibited under Article 5(1)(f), except for medical or safety reasons.

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.

An automated valuation model values the collateral, not the person, so it is not itself listed in Annex III; the EU Mortgage Credit Directive treats property valuation (Article 19) and the creditworthiness assessment of the borrower (Article 18) as separate steps, and Article 18(3) says the creditworthiness assessment must not be based predominantly on the value of the property exceeding the amount of credit, or on an assumption that the property's value will increase. The valuation becomes relevant to Annex III point 5(b), creditworthiness assessment of natural persons, only where its output is built into a separate system that evaluates the borrower's creditworthiness, and whether that happens depends on how the lender designs the credit decision, not on the valuation model itself.

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.

Planning support for advisors is not listed in Annex III. A client facing version must disclose that the client is talking to AI (Article 50). It becomes high risk if it is used to assess the creditworthiness of individuals (Annex III point 5(b)) or for risk assessment and pricing of life or health insurance for individuals (Annex III point 5(c)).

The drafting assistant does not assess creditworthiness, so on its own it is not the Annex III point 5(b) credit scoring system. It helps the lender meet the Article 86 right of affected people to a clear and meaningful explanation of decisions based on such a high risk system. If it is built into the scoring system it shares that system's high risk obligations; as a separate drafting tool its tier depends on its design and on how its output is reviewed. The follow up chat assistant must tell customers they are dealing with an AI system (Article 50).

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 judgments stay with people.

Most personalization and content generation is minimal risk. Providers of systems that generate synthetic audio, image, video or text content must mark the output as artificially generated, and deployers must disclose deep fakes (Article 50(2) and 50(4)). Personalization that deploys manipulative or deceptive techniques, or exploits vulnerabilities due to age, disability or a specific social or economic situation, in a way that causes or is reasonably likely to cause significant harm, is prohibited under Article 5(1)(a) and (b). Using AI to assess creditworthiness or to price life and health insurance is high risk under Annex III point 5(b) and 5(c) and belongs on its own page. Outside the AI Act, the FCA Consumer Duty applies only to FCA regulated firms (the financial services slice of this use case), and the Telephone Consumer Protection Act applies only to campaigns delivered by call or text message in the US.

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.

Surveillance of orders and transactions as such is not listed in Annex III. Where the system monitors and evaluates the behavior of the firm's own staff, in their communications or their trading, it can fall under Annex III point 4(b) (AI used to monitor and evaluate the performance and behavior of persons in work relationships), so the tier depends on whether the system scores individual employees. Inferring employees' emotions from biometric data such as voice recordings is prohibited in the workplace under Article 5(1)(f).

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.

Ranking investment and service prompts for an advisor is not listed in Annex III. It becomes high risk if the system evaluates the creditworthiness of natural persons, for example to decide which clients are offered lending (Annex III point 5(b)), so keep credit decisions out of the prompt engine. It is also high risk if the system itself is used to monitor or evaluate advisors' performance and behavior, for example by scoring or ranking advisors on how they act on prompts (Annex III point 4(b)), so keep adoption reporting separate from performance management.

Recommending restructuring terms for individuals involves assessing their ability to pay, which can amount to evaluating the creditworthiness of natural persons under Annex III point 5(b). Human approval alone does not remove that: the Article 6(3) exception covers only systems that do not materially influence the decision, such as a narrow procedural or preparatory task, and never applies when the system profiles natural persons. A tool that only assembles the case file can fall under the exception; restructuring for companies is outside point 5(b).

Used only for practice and feedback, the simulator is limited risk. Article 50 requires that people know they are interacting with AI unless that is obvious from the context, as it usually is in a training session, and the provider must mark synthetic voice or text output as AI generated in a machine readable format. It becomes high risk under Annex III point 4(b) if its scores are used to evaluate the performance of workers or to decide on their promotion or termination, and can fall under point 3(b) when a vocational training institution uses it to evaluate learning outcomes. Inferring trainees' emotions from voice or face in the workplace is prohibited under Article 5(1)(f), except for medical or safety reasons.

An AML customer risk rating is not listed in Annex III. Article 5(1)(d) prohibits AI risk assessments that predict whether a natural person will commit or will likely commit a criminal offense based solely on profiling of that person or on assessing their personality traits and characteristics; it exempts only AI that supports the human assessment of a person's involvement in a criminal activity, which is already based on objective and verifiable facts directly linked to a criminal activity. An AML customer risk rating built from due diligence attributes, transaction behavior and screening results is itself an automated evaluation of a person's situation and behavior, which is profiling under GDPR Article 4(4), and due diligence facts such as occupation, geography and products are not facts directly linked to a criminal activity, so the rating does not sit squarely inside the exemption. What keeps it a defensible AML due diligence tool rather than an offense prediction is that it does not itself accuse a person of an offense: it sets a level of scrutiny, a human analyst reviews material moves, and regulatory minimum rules sit above the model as hard constraints. A rating driven mainly by nationality or other personal attributes weakens that position further, which is why the proxy discrimination guardrail matters. If the same score is used to evaluate the creditworthiness of natural persons or to establish their credit score, that use falls under Annex III point 5(b) and is high risk, so keep the AML rating and credit decisions separate.

Investment suitability assessment is not listed in Annex III, so the tier depends on design. It becomes high risk where the same system assesses creditworthiness, for example for lending against a portfolio (Annex III point 5(b)). MiFID II suitability duties apply regardless of the AI Act tier.

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.

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

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.

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.

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.

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.

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).

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 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 assistant must make clear that people are dealing with AI, unless that is obvious from the context (Article 50). Preparing a payment the customer approves is not listed in Annex III. It becomes high risk if the same assistant evaluates creditworthiness, for example by deciding on an overdraft or credit line at the moment of payment (Annex III point 5(b)).

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).

Article 50(1): people must be told they are interacting with an AI system unless that is obvious from the context. Camera based emotion recognition of customers, which some of the avatars described here do, is high risk under Annex III point 1(c) and needs the Article 50(3) notice, so leave it out of the design or put it through a separate assessment. An avatar that mimics a real employee or executive may also be deepfake content under Article 50(4), which requires disclosure that the content is artificially generated. General product and service answers are not an Annex III use; the tier would rise if the avatar assessed creditworthiness or priced life or health insurance.

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.

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)).

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.

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).

Article 50(1): the business owner must be informed they are interacting with an AI system, unless that is obvious from the context. Preparing routine transfers, invoices and payroll for an existing business account is not an Annex III use. It would become high risk under Annex III point 5(b) if the agent itself assessed a natural person's creditworthiness, for example to decide whether to extend the account an overdraft or credit line.

An internal drafting and review aid that makes no decisions about people. Article 50 transparency duties apply to generated content: providers must mark synthetic content, and deployers must disclose deep fake images, audio or video. Personalized targeting of individuals is governed mainly by data protection and consumer law rather than the AI Act.

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.

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.

A customer facing collections agent must disclose that it is AI (Article 50). It is not listed in Annex III as long as it applies preapproved arrangement rules and does not itself evaluate creditworthiness; an affordability model that decides who gets which arrangement for individuals should be assessed separately against Annex III point 5(b).

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.

Generating statements and confirmations from system data is not listed in Annex III and takes no decision about credit, insurance or access to essential services. If a customer facing agent takes the requests, Article 50(1) requires telling people they are interacting with an AI system. Under Article 50(2), providers of systems that generate text must mark the output as AI generated, unless the system only performs an assistive function for standard editing, or does not substantially alter the input data provided by the deployer or the semantics thereof; the free text the model drafts here is checked against source, but marking still applies where those exemptions do not.

A drafting copilot whose output an agent reviews and sends falls under the transparency tier at most. When replies are sent without human review, customers interact with the AI system directly, and Article 50(1) requires that they are informed unless this is obvious from the context. Article 50(2) separately requires the provider of a system that generates text to mark its output in a machine readable format as artificially generated, whether or not a person reviews the draft. It becomes high risk only if it is used for a purpose listed in Annex III, such as evaluating eligibility for public benefits or creditworthiness (point 5), or evaluating the performance of the agents who use it (point 4).

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).

Article 50(1): people must be told they are interacting with an AI system unless that is obvious. Finding locations and booking appointments does not fall under any Annex III category. If a healthcare version starts to triage patients by urgency, or a public body uses it to decide eligibility for a public service, reassess it against Annex III point 5.

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.

A customer facing sales agent must make clear that people are talking to an AI system, unless that is obvious (Article 50(1)). Qualifying and routing prospects is not an Annex III use. It becomes high risk where the same system takes on an Annex III task, for example evaluating the creditworthiness of natural persons (Annex III point 5(b)) or assessing risk and pricing for life or health insurance (point 5(c)); those decisions then need the high risk controls.

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 behavior 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 behavior or performance (including through the agent's logs), would need its own assessment.

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

Drafting letters for human approval is not listed in Annex III. The decision the letter communicates may come from a separate high risk system, such as credit scoring (Annex III point 5(b)) or a public body's eligibility decision on benefits (point 5(a)); the drafting tool does not make that decision. Article 50(2) requires the provider of an AI system that generates text to mark the output as artificially generated, which puts this on the limited risk (transparency) tier; this includes an organization that builds its own drafting tool. Article 50(2) does not apply where the AI has only an assistive function for standard editing and does not substantially alter the input data or the semantics of the output.

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 labeled 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.

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 summarizer 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.

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)).

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.

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.

Adverse media and PEP screening for due diligence is not listed in Annex III. It processes personal data, including data about alleged offenses, so GDPR Article 10 and national AML law govern what may be collected and how long it is kept.

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. Behavioral 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.

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.

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.

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.

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 offenses 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.

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.

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 labeled 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.

A validation copilot supports internal governance and is not itself an Annex III use, and its drafts are internal, so Article 50 transparency duties do not normally apply. It often helps validate models that are high risk under Annex III (point 5(b), creditworthiness and credit scoring of natural persons; point 5(c), life and health insurance pricing), and the testing and documentation it supports feed the provider obligations of Articles 9, 11 and 15.

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.

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.

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.

Dispute processing between issuers, acquirers and merchants is not listed in Annex III and 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.

Verifying charges against contracts is not listed in Annex III and is not a practice prohibited by Article 5. The system is internal, so the Article 50(1) duty to tell people they are dealing with AI does not arise; the Article 50(2) duty to mark generated text, such as the discrepancy explanations, falls on the provider of the generative model or system. It supports, but does not take, decisions about individual customers; remediation decisions stay with people.

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.

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.

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' behavior or performance, which falls under Annex III point 4(b).

An internal assistant that screens contracts for compliance with Shariah standards is not listed in Annex III: it assesses contracts, structures and securities, not the creditworthiness of natural persons (Annex III point 5(b)). If a customer facing version answers product questions, it must disclose that people are interacting with an AI system under Article 50(1). National Islamic finance regulators set their own Shariah governance expectations.

Analyzing complaints in aggregate to find causes is not listed in Annex III, is not a practice prohibited by Article 5 and does not decide on individuals. It does not interact with the public, so the disclosure duty in Article 50(1) does not apply; the machine readable marking of generated text in Article 50(2) is a duty of the provider of the generative model or system that writes the summaries. If the same system decided individual complaint outcomes or redress, or its themes were used to evaluate the performance of individual complaint handlers (Annex III point 4), that design would need its own assessment.

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.

Drafting internal policy text for human approval is not an Annex III use and has no direct effect on individuals. The Article 4 AI literacy measures still apply to the staff who use it.

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.

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.