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Article 15 for Fintech AI: Accuracy, Robustness and Cybersecurity

How Article 15 (accuracy, robustness, cybersecurity) applies to fintech AI: the Annex III credit-scoring and insurance hooks, dates, provider and deployer roles, and fines.

Providers of high-risk AI systems, such as credit-scoring software vendors, must design them for appropriate accuracy, robustness and cybersecurity (Article 15).

Fintech is not an Act category. The hooks are Annex III points 5(b), creditworthiness of natural persons, and 5(c), life and health insurance, from 2 December 2027. The provider declares accuracy levels and metrics in the instructions for use (Article 15(3)). Fines go up to EUR 15 million or, for an undertaking, up to 3% of worldwide annual turnover, whichever is higher (Article 99(4)). Next step: list the metrics you will declare.

Article 15 asks for appropriate performance, not a fixed number

Article 15 sets design requirements for the provider. It names no accuracy value for any sector.

  • Art. 15(1)
    Appropriate level, throughout the lifecycle

    High-risk AI systems must be designed and developed to reach an appropriate level of accuracy, robustness and cybersecurity, and to perform consistently in those respects throughout their lifecycle.

  • Art. 15(2)
    Benchmarks are for the Commission to encourage

    The Commission is to encourage, as appropriate, benchmarks and measurement methodologies, in cooperation with stakeholders such as metrology and benchmarking authorities. This is not a duty of the provider.

  • Art. 15(3)
    Declare levels and metrics

    The levels of accuracy and the relevant accuracy metrics must be declared in the accompanying instructions for use.

  • Art. 15(4)
    Resilience against errors, and feedback loops

    Systems must be as resilient as possible against errors, faults or inconsistencies in the system or its environment, in particular from interaction with natural persons or other systems. Technical and organisational measures must be taken; redundancy, backup or fail-safe plans are named as options. A system that keeps learning after it is placed on the market must be developed to eliminate or reduce as far as possible the risk that biased outputs influence future inputs (feedback loops).

  • Art. 15(5)
    Cybersecurity against unauthorised third parties

    Systems must be resilient against attempts by unauthorised third parties to alter their use, outputs or performance by exploiting vulnerabilities. Where appropriate, the technical solutions must include measures against data poisoning, model poisoning, adversarial examples or model evasion, confidentiality attacks and model flaws.

Which fintech AI must meet Article 15

Article 15 binds high-risk AI systems only. The rows below show where fintech AI becomes high-risk.

  • Fintech is not a category in the Act

    The Act has no fintech category. This site uses the word for AI that reaches the Act through two Annex III hooks: point 5(b), creditworthiness and credit scoring of natural persons, and point 5(c), risk assessment and pricing in life and health insurance. Point 5(b) excludes fraud detection. Annex III point 5 does not list anti-money-laundering checks, algorithmic trading, robo-advice, insurance other than life and health insurance, or credit assessment of legal persons. A system can still be high-risk under another point of Annex III.

  • Annex III points 5(b) and 5(c)

    Annex III point 5(b) covers AI systems intended to be used to evaluate the creditworthiness of natural persons or establish their credit score, with the exception of AI systems used for the purpose of detecting financial fraud. Point 5(c) covers AI systems intended to be used for risk assessment and pricing in relation to natural persons in the case of life and health insurance. Under Article 6(2), AI systems referred to in Annex III are considered high-risk. A provider that considers such a system not high-risk under Article 6(3) must document its assessment before the system is placed on the market or put into service, and must register it under Article 49(2). The derogation never applies where the system performs profiling of natural persons. Profiling means profiling as defined in Article 4, point (4), of Regulation (EU) 2016/679 (Article 3(52)); whether a given scoring system performs profiling is not answered by the Act.

  • Provider and deployer

    The provider develops the AI system, or has it developed, and places it on the market or puts it into service under its own name (Article 3(3)); this can be a software vendor or a bank that develops a system for its own use. A natural or legal person, public authority, agency or other body that uses a system under its authority, such as a bank, insurer or lender, is a deployer (Article 3(4)). A deployer becomes a provider if it puts its name or trademark on a high-risk system already on the market, makes a substantial modification that leaves the system high-risk, or changes the intended purpose of a non-high-risk system so that it becomes high-risk (Article 25(1)).

  • Dates

    Annex III points 5(b) and 5(c) apply from 2 December 2027 (Article 113, third paragraph, point (c)). A system placed on the market or put into service before that date is covered only if its design changes significantly afterwards; in any case, providers and deployers of high-risk systems intended to be used by public authorities must take the necessary steps to comply by 2 August 2030 (Article 111(2)).

  • Fines

    Breaches of provider obligations under Article 16 and of deployer obligations under Article 26 can be fined up to EUR 15 million or, for an undertaking, up to 3% of total worldwide annual turnover in the preceding financial year, whichever is higher (Article 99(4)). For SMEs, including start-ups, each fine is capped at whichever is lower (Article 99(6)). The same cap applies to small mid-cap enterprises (Article 3(14b), Article 99(6a)). Each Member State lays down rules on to what extent administrative fines may be imposed on public authorities and bodies established in that Member State (Article 99(8)).

  • Limits of the Act’s scope

    The Act applies to providers that place AI systems on the market or put them into service in the Union, or place general-purpose AI models on the market in the Union, wherever they are established (Article 2(1), point (a)), and to providers and deployers in a third country where the output of the AI system is used in the Union (point (c)). It does not apply to areas outside the scope of Union law and does not affect Member States’ competences on national security, nor to AI systems used exclusively for military, defence or national security purposes (Article 2(3)).

What the Act leaves open for fintech

  • No fintech accuracy values

    Article 15 names no accuracy metric, minimum value, test method or standard for any sector, and none for credit scoring or insurance. The provider declares the levels and relevant metrics (Article 15(3)). Harmonised standards whose references are published in the Official Journal give a presumption of conformity in so far as they cover the requirements (Article 40(1)); a published cybersecurity certificate under Regulation (EU) 2019/881 gives one for the cybersecurity requirements in so far as it covers them (Article 42(2)). Systems that fall within the scope of Regulation (EU) 2024/2847 and meet the conditions in Article 12(1) of that Regulation are deemed to comply with the cybersecurity requirements of Article 15 (Article 42(3)). The Commission is to develop guidelines on the application of the requirements and obligations in Articles 8 to 15 and Articles 25 and 26 (Article 96(1), point (a)).

  • Example: metrics for a credit-scoring model

    Example, not an Act requirement: a provider of a credit-scoring model could declare which accuracy metrics it measured and state the applicant population and period they were measured on.

  • Example: testing for errors and attacks

    Example, not an Act requirement: a provider could test the system with corrupted or out-of-range inputs and with adversarial examples, and keep the results.

Questions about Article 15 in fintech

Does Article 15 set accuracy values for credit scoring?

No. Article 15(1) requires an appropriate level, and Article 15(3) requires the provider to declare the levels and relevant metrics in the instructions for use. The Act names no value, metric or test method for credit scoring or insurance.

Does Article 15 apply to fraud-detection AI?

Article 15 binds high-risk AI systems. Annex III point 5(b) excludes systems used for detecting financial fraud, so such a system is not high-risk through that point. It is high-risk only if another point of Annex III covers it (Article 6(2)).

Who must meet Article 15 when a bank buys a credit-scoring tool?

The provider designs the system to meet Article 15 (Article 16, point (a)). The bank is a deployer and uses the system according to the instructions for use (Article 26(1)). A deployer that puts its own name on the system, makes a substantial modification or changes the intended purpose becomes the provider (Article 25(1)).

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