High-risk AI system

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Glossary · AI and model risk

High-risk AI system

Also called high-risk AI, annex III AI system

Definition

A high-risk AI system is an AI system that the EU AI Act classes as posing significant risk to health, safety or fundamental rights. It covers AI in regulated products and AI used in Annex III areas, including credit scoring of individuals and life and health insurance pricing. Such systems face strict obligations before and after launch.

ANNEX III USERISK CONTROLSCONFORMITY CHECKEU DATABASE
Fig. 1 · High-risk AI system
EU AI Act · Digital omnibus on AI
Key rulesEU AI Act · Digital omnibus on AI
Applies toProviders and deployers of AI systems in the EU
RegionsEU
01

How it works

A bank or insurer first inventories its AI systems and checks each against Annex I and Annex III. Providers of high-risk systems run a risk management system, govern training data, keep technical documentation and logs, design for human oversight and pass a conformity assessment before registering the system. Deployers use systems as instructed, assign trained oversight staff, keep logs and, for credit and insurance uses, carry out a fundamental rights impact assessment.

Financial firms are directly affected because creditworthiness assessment and insurance pricing are listed in Annex III. The digital omnibus, Regulation 2026/1744, moved the start of Annex III duties to 2 December 2027 and Annex I duties to 2 August 2028. Breaches can lead to fines under Article 99 of the Act. Firms are building inventories and model governance now.

Step 1Inventory AIList every AI system and its intended use.
Step 2ClassifyCheck each against Annex I and Annex III categories.
Step 3Build controlsApply risk, data, logging and human oversight requirements.
Step 4Assess conformityComplete conformity assessment and register in EU database.
Step 5MonitorRun post-market monitoring and report serious incidents.
02

The rules

EU · 1 August 2024EU AI ActRegulation (EU) 2024/1689 laying down harmonised rules on artificial intelligence

Classifies AI by risk and sets obligations for high-risk systems under Article 6 and Annexes I and III.

Providers and deployers of AI systems in the EU
EU · 27 July 2026Digital omnibus on AIRegulation (EU) 2026/1744 amending Regulation (EU) 2024/1689

Moves Annex III high-risk obligations to 2 December 2027 and Annex I obligations to 2 August 2028.

Providers and deployers of high-risk AI systems
03

Common questions

Is credit scoring a high-risk AI use?

Yes. Annex III of the EU AI Act lists AI systems used to evaluate the creditworthiness of natural persons or establish their credit score as high risk. AI used only to detect financial fraud is excluded from this category.

When do high-risk AI rules apply?

After the digital omnibus, Regulation 2026/1744, obligations for Annex III high-risk systems apply from 2 December 2027. Obligations for AI that is a safety component of products covered by Annex I apply from 2 August 2028.

Can an Annex III system avoid the high-risk label?

Under Article 6(3), a provider can show that an Annex III system does not pose a significant risk, for example because it performs a narrow procedural task. The provider documents that assessment. Systems that profile individuals are always high risk.

What is the difference between a provider and a deployer?

A provider develops an AI system or has it developed and places it on the market under its own name. A deployer uses the system in its professional activity. A bank that buys a credit scoring model is usually a deployer, with lighter but still binding duties.