{"answer_id":"praxikon:eu:ai-act:answer:kredietscore-verzekering","canonical_page":"https://www.praxikon.com/en/antwoord/kredietscore-verzekering","query":"We use AI for creditworthiness or insurance pricing. What applies?","lang":"en","view":"full","mode":"scenario","question":"We use AI for creditworthiness or insurance pricing. What applies?","situation":"AI determining creditworthiness or credit scores, or risk and premium setting for life or health insurance.","likely_role":"Credit or insurance deployer","note":"These use cases sit in Annex III points 5(b) and 5(c) and are the only private category that also carries the FRIA duty. Both follow the timeline to 2 December 2027.","matched_terms":[],"dataset":{"id":"praxikon:sys:registry:dataset:ai-act-implementation-graph","version":"2.2.0","schema_version":"1.5.0","effective_at":"2026-08-08T00:00:00.000Z","known_at":"2026-09-06T00:00:00.000Z","last_reviewed_at":"2026-08-08T00:00:00.000Z","licence":"https://www.praxikon.com/nl/legal/terms","canonical_url":"https://www.praxikon.com/api/v1/entities"},"obligations":[{"slug":"annex-iii-high-risk","label":"Annex III: high-risk AI","summary":"Classification route for standalone high-risk AI systems under Article 6(2) and Annex III.","legal_status":"upcoming","deadline_at":"2027-12-02T00:00:00.000Z","high_risk_regime_from":null,"human_page":"https://www.praxikon.com/en/verplichtingen/annex-iii-high-risk","api":"https://www.praxikon.com/api/v1/obligations?lang=en","official_source":"https://eur-lex.europa.eu/eli/reg/2026/1744/oj","citations":[{"kind":"official_fact","statement":"The core rules in Chapter III, Sections 1 to 3, for systems under Article 6(2) and Annex III become applicable on 2 December 2027.","source_id":"praxikon:eu:ai-act:source:reg-eu-2026-1744","source_locator":"Amended Article 113, Article 6(2) and Annex III application date","source_url":"https://eur-lex.europa.eu/eli/reg/2026/1744/oj","eli":"http://data.europa.eu/eli/reg/2026/1744/oj"},{"kind":"editorial_interpretation","statement":"The later application date does not remove the classification question. An early classification record avoids design and procurement decisions without evidence.","source_id":"praxikon:eu:ai-act:source:reg-eu-2024-1689","source_locator":"Article 6 and Annex III","source_url":"https://eur-lex.europa.eu/eli/reg/2024/1689/oj","eli":"http://data.europa.eu/eli/reg/2024/1689/oj"},{"kind":"recommended_action","statement":"Document now the intended purpose, Annex III point, Article 6(3) assessment, profiling and selected registration path.","source_id":"praxikon:eu:ai-act:source:reg-eu-2024-1689","source_locator":"Article 6(2)-(4), Article 49 and Annex III","source_url":"https://eur-lex.europa.eu/eli/reg/2024/1689/oj","eli":"http://data.europa.eu/eli/reg/2024/1689/oj"}]},{"slug":"article-27-fria","label":"Article 27: FRIA","summary":"Fundamental rights impact assessment before deploying certain high-risk AI systems.","legal_status":"upcoming","deadline_at":"2027-12-02T00:00:00.000Z","high_risk_regime_from":null,"human_page":"https://www.praxikon.com/en/verplichtingen/article-27-fria","api":"https://www.praxikon.com/api/v1/obligations?lang=en","official_source":"https://eur-lex.europa.eu/eli/reg/2024/1689/oj","citations":[{"kind":"official_fact","statement":"The listed deployers must perform a FRIA before deployment. For this Annex III route, the obligation follows the application date of 2 December 2027.","source_id":"praxikon:eu:ai-act:source:reg-eu-2024-1689","source_locator":"Article 27(1)-(5)","source_url":"https://eur-lex.europa.eu/eli/reg/2024/1689/oj","eli":"http://data.europa.eu/eli/reg/2024/1689/oj"},{"kind":"official_fact","statement":"The listed deployers must perform a FRIA before deployment. For this Annex III route, the obligation follows the application date of 2 December 2027.","source_id":"praxikon:eu:ai-act:source:reg-eu-2026-1744","source_locator":"Amended application schedule and Article 27 DPIA cross-reference","source_url":"https://eur-lex.europa.eu/eli/reg/2026/1744/oj","eli":"http://data.europa.eu/eli/reg/2026/1744/oj"},{"kind":"editorial_interpretation","statement":"A FRIA is not a generic risk assessment for every AI system. First establish the system route, Annex III category and type of deployer.","source_id":"praxikon:eu:ai-act:source:reg-eu-2024-1689","source_locator":"Article 27(1)","source_url":"https://eur-lex.europa.eu/eli/reg/2024/1689/oj","eli":"http://data.europa.eu/eli/reg/2024/1689/oj"},{"kind":"recommended_action","statement":"Link the FRIA to the AI inventory and, where relevant, the DPIA. Keep scope, affected groups, mitigations, residual risks and notification in one versioned record.","source_id":"praxikon:eu:ai-act:source:reg-eu-2026-1744","source_locator":"Article 27 amendment on DPIA inclusion or cross-reference","source_url":"https://eur-lex.europa.eu/eli/reg/2026/1744/oj","eli":"http://data.europa.eu/eli/reg/2026/1744/oj"}]},{"slug":"article-26-deployer-obligations","label":"Article 26: obligations of deployers of high-risk AI systems","summary":"Twelve paragraphs governing day-to-day use: use in line with the instructions, human oversight by competent people, input data, monitoring and notification, log retention, informing workers before deployment, registration by public authorities and informing the people about whom decisions are made.","legal_status":"upcoming","deadline_at":"2027-12-02T00:00:00.000Z","high_risk_regime_from":null,"human_page":"https://www.praxikon.com/en/verplichtingen/article-26-deployer-obligations","api":"https://www.praxikon.com/api/v1/obligations?lang=en","official_source":"https://eur-lex.europa.eu/eli/reg/2024/1689/oj","citations":[{"kind":"official_fact","statement":"Article 26 imposes twelve paragraphs on deployers of high-risk AI systems. Paragraph 1 requires appropriate technical and organisational measures to ensure use in accordance with the accompanying instructions for use. Paragraph 2 requires assigning human oversight to natural persons who have the necessary competence, training and authority, as well as the necessary support. Paragraph 3 leaves other obligations and the freedom to organise one's own resources unaffected. Paragraph 4 requires, to the extent the deployer exercises control over the input data, that such data is relevant and sufficiently representative in view of the intended purpose. Paragraph 5 requires monitoring on the basis of the instructions for use and informing the provider in accordance with Article 72; where there is reason to consider that use may result in a risk within the meaning of Article 79(1), the deployer shall without undue delay inform the provider or distributor and the relevant market surveillance authority and suspend use, and upon identifying a serious incident shall immediately inform first the provider and then the importer or distributor and the market surveillance authorities. Paragraph 6 requires keeping the automatically generated logs under the deployer's control for a period appropriate to the intended purpose and of at least six months, unless Union or national law provides otherwise. Paragraph 7 requires deployers who are employers to inform workers' representatives and the affected workers, before putting into service or using the system at the workplace, that they will be subject to its use. Paragraph 8 imposes the registration obligations of Article 49 on public authorities and Union institutions, bodies, offices and agencies and prohibits use of a system not registered in the EU database referred to in Article 71. Paragraph 9 links the information provided under Article 13 to the data protection impact assessment under Article 35 of Regulation (EU) 2016/679. Paragraph 10 sets additional conditions for post-remote biometric identification in law enforcement. Paragraph 11 opens with the words without prejudice to Article 50 of this Regulation and requires deployers of Annex III systems that make or assist in making decisions related to natural persons to inform those persons that they are subject to the use of the system; for high-risk AI systems used for law enforcement purposes Article 13 of Directive (EU) 2016/680 applies. The transparency obligations of Article 50 have applied since 2 August 2026 and are separate from the date on which paragraph 11 starts to apply. Paragraph 12 requires cooperation with the competent authorities.","source_id":"praxikon:eu:ai-act:source:reg-eu-2024-1689","source_locator":"Article 26(1)-(12)","source_url":"https://eur-lex.europa.eu/eli/reg/2024/1689/oj","eli":"http://data.europa.eu/eli/reg/2024/1689/oj"},{"kind":"editorial_interpretation","statement":"The 2 December 2027 date invites postponement, but two elements are preparation work today. Paragraph 7 requires you to inform workers' representatives and the affected workers before the system is put into service at the workplace, and that information is provided, where applicable, in line with existing rules and practice on informing workers. That touches employee participation, and such a process takes months rather than weeks in practice, so a system that must go live in 2027 is discussed in 2026. Paragraph 2 also connects to the human oversight that Article 14 imposes on system design: you must designate natural persons with competence, training, authority and support. That is emphatically not the same as the measures obligation in Article 4. Article 4 requires measures supporting AI literacy and does not require you to guarantee a particular level for individuals; Article 26(2) requires identifiable overseers with a mandate. Conflating the two leaves you believing a generic e-learning is enough while still having no overseer with room to decide. A third underestimated element is paragraph 11: informing the people about whom an Annex III system makes or helps make decisions is visible customer or candidate communication that you have to design across your own organisation.","source_id":"praxikon:eu:ai-act:source:reg-eu-2024-1689","source_locator":"Article 26(1)-(12)","source_url":"https://eur-lex.europa.eu/eli/reg/2024/1689/oj","eli":"http://data.europa.eu/eli/reg/2024/1689/oj"},{"kind":"recommended_action","statement":"Draw up now a list of the systems likely to qualify as high-risk from 2 December 2027 and add three columns: who exercises human oversight and with what mandate, when you will inform the works council and the affected workers, and how the persons concerned will receive the notice under paragraph 11. Plan the employee participation process a year ahead.","source_id":"praxikon:eu:ai-act:source:reg-eu-2024-1689","source_locator":"Article 26(1)-(12)","source_url":"https://eur-lex.europa.eu/eli/reg/2024/1689/oj","eli":"http://data.europa.eu/eli/reg/2024/1689/oj"}]},{"slug":"article-4-ai-literacy","label":"Article 4: AI literacy","summary":"Providers and deployers take measures that support the development of AI literacy.","legal_status":"applicable","deadline_at":"2025-02-02T00:00:00.000Z","high_risk_regime_from":null,"human_page":"https://www.praxikon.com/en/verplichtingen/article-4-ai-literacy","api":"https://www.praxikon.com/api/v1/obligations?lang=en","official_source":"https://eur-lex.europa.eu/eli/reg/2026/1744/oj","citations":[{"kind":"official_fact","statement":"Since 27 July 2026, providers and deployers must take measures supporting the development of AI literacy. The provision does not require a guaranteed individual level.","source_id":"praxikon:eu:ai-act:source:reg-eu-2026-1744","source_locator":"Amendment of Article 4; entry into force 27 July 2026","source_url":"https://eur-lex.europa.eu/eli/reg/2026/1744/oj","eli":"http://data.europa.eu/eli/reg/2026/1744/oj"},{"kind":"editorial_interpretation","statement":"Evidence is primarily a proportionate record of measures by role and context, not one prescribed course or certificate.","source_id":"praxikon:eu:ai-act:source:commission-ai-literacy-qa","source_locator":"Questions on measures, formats, certificates and records","source_url":"https://digital-strategy.ec.europa.eu/en/faqs/ai-literacy-questions-answers","eli":null},{"kind":"recommended_action","statement":"Inventory roles and AI systems, select appropriate measures and record the choice, implementation and periodic review.","source_id":"praxikon:eu:ai-act:source:commission-ai-literacy-qa","source_locator":"Implementation examples and evidence guidance","source_url":"https://digital-strategy.ec.europa.eu/en/faqs/ai-literacy-questions-answers","eli":null}]},{"slug":"article-20-corrective-actions","label":"Article 20: corrective actions and duty of information","summary":"A provider that considers, or has reason to consider, that a high-risk AI system it has placed on the market or put into service is not in conformity with the Regulation must immediately take the necessary corrective actions and inform the distributors accordingly, and, where applicable, also the deployers, the authorised representative and the importers. Where that system also presents a risk within the meaning of Article 79(1), the provider must immediately investigate the causes and inform the competent market surveillance authorities and, where applicable, the notified body that issued a certificate under Article 44.","legal_status":"upcoming","deadline_at":"2027-12-02T00:00:00.000Z","high_risk_regime_from":null,"human_page":"https://www.praxikon.com/en/verplichtingen/article-20-corrective-actions","api":"https://www.praxikon.com/api/v1/obligations?lang=en","official_source":"https://eur-lex.europa.eu/eli/reg/2024/1689/oj","citations":[{"kind":"official_fact","statement":"Paragraph 1. Providers of high-risk AI systems which consider or have reason to consider that a high-risk AI system that they have placed on the market or put into service is not in conformity with this Regulation shall immediately take the necessary corrective actions to bring that system into conformity, to withdraw it, to disable it, or to recall it, as appropriate. They shall inform the distributors of the high-risk AI system concerned and, where applicable, the deployers, the authorised representative and importers accordingly. Paragraph 2. Where the high-risk AI system presents a risk within the meaning of Article 79(1) and the provider becomes aware of that risk, it shall immediately investigate the causes, in collaboration with the reporting deployer, where applicable, and inform the market surveillance authorities competent for the high-risk AI system concerned and, where applicable, the notified body that issued a certificate for that high-risk AI system in accordance with Article 44, in particular, of the nature of the non-compliance and of any relevant corrective action taken.","source_id":"praxikon:eu:ai-act:source:reg-eu-2024-1689","source_locator":"Article 20(1)-(2)","source_url":"https://eur-lex.europa.eu/eli/reg/2024/1689/oj","eli":"http://data.europa.eu/eli/reg/2024/1689/oj"},{"kind":"official_fact","statement":"For the Annex III route this requirement applies from 2 December 2027; for high-risk AI in regulated products (Annex I) from 2 August 2028.","source_id":"praxikon:eu:ai-act:source:reg-eu-2026-1744","source_locator":"Article 1, point (40)(b), of Regulation (EU) 2026/1744, replacing Article 113, third paragraph, point (c), of Regulation (EU) 2024/1689","source_url":"https://eur-lex.europa.eu/eli/reg/2026/1744/oj","eli":"http://data.europa.eu/eli/reg/2026/1744/oj"},{"kind":"editorial_interpretation","statement":"This provision is rarely read as a procedure, and that is exactly where it goes wrong. Article 20 places four measures side by side that differ sharply in practice, and those four are not legally equivalent. Recall and withdrawal are defined in Article 3(16) and (17), and the knowledge base carries those terms separately; the difference between them is the point in the chain. Bringing a system into conformity is the patch. Disabling is the odd one out: it is practically the heaviest switch, because it stops a customer who is running the system, and it is at the same time the only one of the four the Regulation nowhere defines. Anyone who copies that word into a contract or procedure without deciding for themselves what it means leaves the heaviest measure the vaguest. The second half is the notification, and in practice that is what fails most often. Paragraph 1 asks you to reach your distributors and, where applicable, your deployers, authorised representatives and importers, which is only possible if you hold a current list of who runs the system in which version and through which contact you reach them. That list is not a by-product of your CRM: resale, white labelling and integration mean you have customers you do not know.","source_id":"praxikon:eu:ai-act:source:reg-eu-2024-1689","source_locator":"Article 20(1)-(2)","source_url":"https://eur-lex.europa.eu/eli/reg/2024/1689/oj","eli":"http://data.europa.eu/eli/reg/2024/1689/oj"},{"kind":"editorial_interpretation","statement":"Paragraph 2 and Article 73 are often built as a single reporting channel, and that goes wrong in two ways. The trigger differs: Article 73 concerns a serious incident that has occurred, Article 20(2) a risk within the meaning of Article 79(1), that is, a risk to the health, safety or fundamental rights of persons. That is not a tidy split between past and future: a serious incident that has occurred usually also means the system presents a risk, so in practice both provisions often fire at the same time. Nor do the recipients differ entirely, because both routes run to market surveillance authorities. The difference sits in the detail: Article 73(1) points to the authorities of the Member States where the incident occurred, Article 20(2) to the authorities competent for the system concerned, and only Article 20(2) adds the notified body that issued a certificate under Article 44. Only Article 73, moreover, sets hard deadlines. So build one internal process with two exits, not two separate channels and not one channel that forgets the notified body.","source_id":"praxikon:eu:ai-act:source:reg-eu-2024-1689","source_locator":"Article 20(2), Article 73(1)-(2) and Article 79(1)","source_url":"https://eur-lex.europa.eu/eli/reg/2024/1689/oj","eli":"http://data.europa.eu/eli/reg/2024/1689/oj"},{"kind":"recommended_action","statement":"Write out the four measures in paragraph 1 as four concrete scenarios with an owner, a decision maker and a lead time, and decide for yourself what disabling means in your system, because the Regulation does not define that term. Test at least once whether you can actually disable or recall a system without needing a fresh decision to do so. Also keep a record, per system version, of who runs it and through which contact you reach that party, and record which signal meets the \"reason to consider\" threshold in your organisation, so that the moment of becoming aware is demonstrable rather than something reconstructed after the fact.","source_id":"praxikon:eu:ai-act:source:reg-eu-2024-1689","source_locator":"Article 20(1)-(2)","source_url":"https://eur-lex.europa.eu/eli/reg/2024/1689/oj","eli":"http://data.europa.eu/eli/reg/2024/1689/oj"}]}],"conditional":[{"slug":"article-61-informed-consent","id":"praxikon:eu:ai-act:obligation:article-61-informed-consent","label":"Article 61: informed consent of test subjects for testing in real world conditions","status":"possibly_applies","source_locator":"Article 60(4), point (i), with Article 61(1)","addressee":"reader","human_page":"https://www.praxikon.com/en/verplichtingen/article-61-informed-consent"}],"sources":[{"id":"praxikon:eu:ai-act:source:reg-eu-2024-1689","title":"EU Artificial Intelligence Act 2024/1689","publisher":"European Parliament and Council","canonical_url":"https://eur-lex.europa.eu/eli/reg/2024/1689/oj","eli":"http://data.europa.eu/eli/reg/2024/1689/oj","source_version":"original-oj-2024-07-12","verified_at":"2026-08-08T00:00:00.000Z"},{"id":"praxikon:eu:ai-act:source:reg-eu-2026-1744","title":"Digital Omnibus on AI 2026/1744","publisher":"European Parliament and Council","canonical_url":"https://eur-lex.europa.eu/eli/reg/2026/1744/oj","eli":"http://data.europa.eu/eli/reg/2026/1744/oj","source_version":"official-journal-2026-07-24","verified_at":"2026-08-08T00:00:00.000Z"},{"id":"praxikon:eu:ai-act:source:commission-ai-literacy-qa","title":"AI literacy questions and answers","publisher":"European Commission","canonical_url":"https://digital-strategy.ec.europa.eu/en/faqs/ai-literacy-questions-answers","eli":null,"source_version":"updated-2026-07-27","verified_at":"2026-08-08T00:00:00.000Z"},{"id":"praxikon:eu:ai-act:source:commission-draft-high-risk-classification-guidelines","title":"Draft guidelines on the classification of high-risk AI systems","publisher":"European Commission (AI Office)","canonical_url":"https://digital-strategy.ec.europa.eu/en/library/draft-commission-guidelines-classification-high-risk-ai-systems","eli":null,"source_version":"draft-for-consultation-2026-05-19","verified_at":"2026-08-08T00:00:00.000Z"}],"first_actions":[{"label":"Justify the Article 6(3) exception against each individual condition","summary":"Name which of the four Article 6(3) conditions you invoke, with facts, and separately justify why the system poses no significant risk of harm to health, safety or fundamental rights and does not materially influence the outcome of decision making."},{"label":"Map the affected groups and their specific risks of harm","summary":"Name the categories of natural persons and groups likely to be affected by the use in this specific context, and work out the specific risks of harm per category, using the information the provider supplied under Article 13."},{"label":"Assign human oversight and give those people a mandate","summary":"Name, per high-risk system, who exercises oversight, and ensure that person has the competence, training, authority and support to actually set the output aside."}],"evidence":[{"label":"Article 49(2) registration record for the system assessed as not high-risk","summary":"Proof that the system for which you invoke the Article 6(3) exception is registered as Article 49(2) requires, with the registration number linked to the underlying assessment.","url":null},{"label":"Notification to the market surveillance authority with the completed template","summary":"The sent notification through which you report the assessment results to the market surveillance authority, with the completed template attached, plus date of dispatch and acknowledgement of receipt.","url":null},{"label":"Deployment dossier: logs, worker information and information to affected persons","summary":"The dossier that shows you retain the logs, that you informed workers and their representatives in time, and that the people about whom decisions are made are aware of it.","url":null}],"guidance":[{"label":"Article 6 has two separate routes to high-risk","statement":"The European Commission's draft guidelines on the classification of high-risk AI of 19 May 2026, which are expressly non-binding, state in paragraph (7) that an AI system is high-risk in two scenarios: first, where it is intended to be used as a safety component of a product, or is itself a product, covered by the Union harmonisation legislation listed in Annex I and required to undergo third-party conformity assessment; and second, where it falls within one of the use cases in the areas listed in Annex III. Paragraph (448) of those same draft guidelines notes that the Article 113 application dates have been postponed by the AI Omnibus to 2 December 2027 for the Article 6(2) route and 2 August 2028 for the Article 6(1) route.","source_locator":"Draft guidelines on high-risk AI classification (19 May 2026), General principles chapter, section II, paragraph (7); section V, paragraph (448)"},{"label":"Broadly positioned and general purpose AI systems: a disclaimer is not enough","statement":"According to the non-binding draft guidelines of 19 May 2026 on the classification of high-risk AI, paragraph (12) provides that where the instructions for use, contractual arrangements, terms of service, usage policy, promotional and sales materials or technical documentation present the AI system as broadly applicable across a generality of contexts and functions, and do not consistently limit its application or exclude high-risk uses, the system's intended purpose will be deemed to also encompass high-risk use cases and therefore qualify as high-risk. Under these draft guidelines this applies in particular where such uses are feasible and reasonably foreseeable given the system's functionalities and capabilities. The same paragraph states that merely asserting, for example in the terms of service, that high-risk uses are excluded is insufficient where the provider's overall presentation, examples or product positioning effectively provides for or promotes such uses, and that any limitations of use must be described clearly, concretely and coherently across all materials.","source_locator":"Draft guidelines on high-risk AI classification (19 May 2026), General principles chapter, section II.2, paragraph (12)"},{"label":"High-risk does not mean prohibited, and not high-risk does not mean permitted","statement":"The draft guidelines of 19 May 2026 on the classification of high-risk AI, which are not binding, state in paragraph (3) that the fact an AI system is listed as an example in these guidelines does not mean its use should automatically be considered lawful, since such use would still need to comply with other applicable legislation, and in paragraph (4) that the scope of these guidelines is limited to whether an AI system is high-risk or not. In the Annex III chapter of this draft, paragraph (68) states that classifying systems as high-risk under Article 6(2) does not mean their use is prohibited, but that those systems are subject to appropriate requirements. Paragraphs (82) and (83) of this draft explain the wording in so far as their use is permitted under relevant Union or national law and state that falling within a use case does not necessarily mean the system may lawfully be used in those cases, that in addition to the prohibitions other provisions of Union or national law may restrict use, and that under Article 2(9) the AI Act applies without prejudice to rules on consumer protection, product safety and data protection.","source_locator":"Draft guidelines on high-risk AI classification (19 May 2026), General principles chapter, paragraphs (3) and (4); Annex III chapter, paragraph (68) and section 2.6, paragraphs (82) and (83)"},{"label":"Split and agentic architectures are assessed as a whole","statement":"The non-binding draft guidelines of 19 May 2026 provide in paragraphs 75, 76 and 90 that where several AI systems form part of a more complex whole and their combined intended purpose or joint outputs materially influence an individual decision, that configuration is treated as a single AI system for classification. The draft expressly states that split architectures are assessed as a whole to prevent circumvention by system design, that exemptions for individual modules do not apply where the overall configuration influences key aspects of the decision, and that this also extends to complex interconnected setups such as agentic AI systems whose linked actions jointly serve a high-risk purpose. Under the same draft, strictly procedural or preparatory functions do remain eligible for exemption where they are genuinely separable from the system and do not structure or feed outputs that materially influence the examination of an individual case.","source_locator":"Section IV.2.3, paragraphs 75 and 76, and section IV.2.7.1 paragraph 90"}],"examples":[{"label":"Money laundering detection by an accounting firm under its own legal duty","situation":"An accounting firm deploys an AI system that detects money laundering, in order to comply with its own obligations under EU anti-money laundering legislation.","outcome":"The Commission draft guidelines of 19 May 2026 address this case when determining whether an application falls under Annex III. The document is a consultation version: non-binding and not yet final.","lesson":"Check whether you are meeting your own legal duty or taking over a task from a public authority, because only in the second case do you act on its behalf and enter the law enforcement regime.","source_locator":"Draft guidelines on high-risk AI classification, 19 May 2026, annex on Annex III","provenance":"official"},{"label":"Company creditworthiness based on corporate financials","situation":"A provider develops a system assessing the creditworthiness of companies by evaluating their company data, balance sheets and financial statements. In a variant, the owner of a legal entity is assessed to back a company loan.","outcome":"The Commission draft guidelines of 19 May 2026 address this case when determining whether an application falls under Annex III. The document is a consultation version: non-binding and not yet final.","lesson":"Decide in advance whether natural persons form part of your intended purpose, because a system that also evaluates their personal finances falls within point 5(b) as a whole, regardless of its corporate focus.","source_locator":"Draft guidelines on high-risk AI classification, 19 May 2026, annex on Annex III","provenance":"official"},{"label":"Corporate creditworthiness based on balance sheets and financial statements","situation":"A provider develops an AI system that assesses the creditworthiness of companies using company data, balance sheets and financial statements. The situation where the owner of a legal entity is assessed as backing for a company loan is also addressed.","outcome":"The Commission draft guidelines of 19 May 2026 address this case when determining whether an application falls under Annex III. The document is a consultation version: non-binding and not yet final.","lesson":"An assessment remains corporate as long as the credit accrues to the company, so even an owner backing a company loan does not turn your system into an evaluation of a natural person.","source_locator":"Draft guidelines on high-risk AI classification, 19 May 2026, annex on Annex III","provenance":"official"},{"label":"Credit score of a business owner based solely on business data","situation":"A provider develops an AI system that establishes the credit score of the owner of a small business or of a company that is not a legal entity. The system uses only business or company data.","outcome":"The Commission draft guidelines of 19 May 2026 address this case when determining whether an application falls under Annex III. The document is a consultation version: non-binding and not yet final.","lesson":"Limit your system demonstrably to business data if you want to stay outside point 5(b), because the moment it also draws on the owner personal finances you are evaluating a natural person.","source_locator":"Draft guidelines on high-risk AI classification, 19 May 2026, annex on Annex III","provenance":"official"}],"standards":[],"definitions":[],"answer_page":"https://www.praxikon.com/en/antwoord/kredietscore-verzekering","follow_up_questions":[{"question":"We use AI in recruitment and selection. Is that high risk?","url":"https://www.praxikon.com/en/antwoord/ai-werving-selectie"},{"question":"We use AI in education or assessment. Is that high risk?","url":"https://www.praxikon.com/en/antwoord/onderwijs-toetsing"},{"question":"What did the Digital Omnibus shift and what still applies as planned?","url":"https://www.praxikon.com/en/antwoord/uitstel-digital-omnibus"}],"disclaimer":"General interpretation, not legal advice. The official source remains authoritative.","methodology":"https://www.praxikon.com/en/methodologie"}