Question 1

Does my credit-scoring AI count as high-risk under the EU AI Act?

Accepted Answer

Almost certainly yes. Annex III, Category 5(b) classifies AI systems used to evaluate the creditworthiness of natural persons or establish their credit score as high-risk, with a specific exception only for AI used solely for fraud detection. If your system produces scores, ratings, or decisions that affect access to credit, it is high-risk.

Question 2

What does Annex III §5 cover for fintech?

Accepted Answer

Annex III §5 covers AI systems in the domain of access to essential private services and benefits. Sub-category 5(a) covers risk assessment and pricing in life and health insurance. Sub-category 5(b) covers creditworthiness evaluation and credit scoring. Sub-category 5(c) covers social benefit eligibility assessment. Fraud detection systems are explicitly excluded from 5(b).

Question 3

When does the August 2026 deadline apply to fintech AI?

Accepted Answer

High-risk AI system obligations under Articles 9–49 — including risk management, data governance, transparency, human oversight, and Annex IV documentation — apply from August 2, 2026. If your credit-scoring or risk-assessment AI system is deployed or placed on the EU market, you need to be compliant by that date.

Question 4

Do financial regulations like MiFID II or DORA overlap with the EU AI Act?

Accepted Answer

There is partial overlap, particularly around risk management requirements, but they are separate obligations. MiFID II covers investment services; DORA covers digital operational resilience for financial entities. Neither replaces EU AI Act obligations for AI systems specifically. Scanara maps findings to the EU AI Act and flags relevant cross-regulation overlap where it applies.

Question 5

How long does an Annex IV technical documentation package take to produce?

Accepted Answer

Manually, producing Annex IV documentation for a high-risk AI system typically takes 40–80 hours for a technical writer working with engineering input. Scanara generates the initial documentation package automatically from scan results, reducing that effort by 70–80%. The remaining work is review and sign-off, not production.

EU AI Act for Fintech AI Companies — Scanara

Annex III §5 — High-Risk Classification

Why fintech AI compliance is complex

Annex III §5 exposure is broad

Rapid regulatory timelines

EU market access at stake

Scanara for fintech AI compliance

Annex III automatic classification

Credit-scoring specific rules

Rapid AIRA for fast release cycles

Automated Annex IV documentation

The cost of non-compliance for fintech

Frequently asked questions

Scan your fintech AI systems

How Scanara Helps