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Five questions covering all three regulatory regimes that apply to credit-scoring AI: EU AI Act Annex III(5)(b) + Article 27 FRIA, GDPR Article 22 automated-decision-making, and Consumer Credit Directive Article 18 explainability. Get a single combined obligations list you can take to your legal team.
Sources: AI Act + GDPR + Consumer Credit Directive. Self-assessment, not legal advice.
Annex III(5)(b) explicitly covers AI used to evaluate creditworthiness of natural persons or establish their credit score. Pure B2B corporate ratings are out of scope unless personal guarantees from natural persons are part of the decision.
Full walkthrough of Annex III(5)(b) classification, the FRIA process specialised for credit, GDPR Article 22 + EDPB WP251, CCD Article 18 explainability, the alternative-credit-scoring Article 5(1)(c) trap, and B2B vs natural-person decision logic.
