Credit / loan eligibility decisioning
High-risk plus rights-affecting — fair-lending and model-risk stack on top of the Act.
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AI Compliance Readiness Navigator
Context
An AI system scoring loan and credit-eligibility decisions. It's a rights-affecting decision on people's access to an essential service, on sensitive financial data — the highest-scrutiny corner of the Act, with a fair-lending and model-risk overlay layered on.
The decision
Design the overlay in, not on: this is high-risk under the Act and rights-affecting, so fair-lending testing, adverse-action reason codes, and SR 11-7 model risk aren't add-ons — they're the build spec.
What most miss
Teams treat the EU AI Act obligations as the whole checklist and forget the sectoral overlay (ECOA/fair-lending, model-risk governance) that regulators actually examine first in finance.
Stakes
Miss the fair-lending overlay and the model clears the Act but fails the exam that shuts lending down.
First-hand · Engagement Leadership · verified 2026-07-03
Sources: Regulated lending / credit-decisioning delivery (first-hand, financial services); EU AI Act high-risk structure + ECOA / SR 11-7 overlay (illustrative, not legal advice)