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In our previous article, we explored the ongoing challenge of balancing innovation and regulation in the financial sector, particularly as AI continues to transform how institutions operate. We also discussed the immense potential of AI to drive efficiency, enhance decision-making, and improve customer experiences, all while navigating the complex regulatory landscape shaped by the European Union’s AI Act.
As we continue this series, it’s crucial to delve deeper into one of the key aspects of the EU AI Act: the categorization of AI applications based on risk levels. The Act’s framework introduces specific classifications - unacceptable, high, medium, and low risk - that financial institutions must understand to ensure compliance and maintain a competitive edge.
In this article, we break down what financial institutions need to know about these risk categories. Understanding and properly managing these risks is essential for institutions looking to leverage AI while adhering to the stringent regulatory requirements that govern its use.
Unacceptable-risk AI applications are those deemed to pose a serious threat to fundamental rights and societal well-being. These systems are outright banned under the EU AI Act. For financial institutions, this category includes AI systems that could potentially manipulate human behavior or infringe on personal integrity, such as AI-driven social scoring systems. While such applications may seem distant from the current financial sector’s focus, the evolving nature of AI technologies means that financial institutions must remain vigilant against deploying or developing systems that could be classified under this category.
High-risk AI systems are those with the potential for significant impact on individuals and society, particularly in critical areas such as finance. These may include AI models used for creditworthiness assessments, fraud detection, and algorithmic trading. Financial institutions employing high-risk AI must comply with stringent regulatory requirements, including:
Institutions must implement robust risk management systems throughout the AI system’s lifecycle.
Ensuring data used in training, validation, and testing is accurate, representative, and free from bias is crucial.
Detailed documentation must be maintained to demonstrate compliance and facilitate regulatory audits.
Even in highly automated processes, human oversight is mandatory to mitigate risks associated with AI decisions.
Institutions must ensure that their AI systems operate transparently, with mechanisms in place to trace decision-making processes.
Compliance with these requirements is not just a legal obligation but a strategic imperative. High-risk AI applications, when properly managed, offer significant advantages in terms of efficiency, accuracy, and profitability. However, failure to comply can result in substantial fines and reputational damage.
Limited-risk systems have a lower potential for harm but still require clear communication to users that AI is in use. In the financial sector, this might include AI-driven chatbots or tools for customer service automation. While the regulatory burden is lighter compared to high-risk systems, institutions must still ensure that their AI applications are transparent and do not infringe on individual rights.
Financial institutions using limited-risk AI applications should focus on maintaining clear disclosure practices and providing users with sufficient information to make informed decisions about interacting with AI systems. This not only helps in compliance but also builds trust with clients and stakeholders.
Low-risk AI applications pose minimal or no risk to individuals or society. These include systems that do not process personal data or make decisions affecting individuals, such as predictive maintenance tools or certain process automation systems. For financial institutions, low-risk AI tools can be implemented with minimal regulatory oversight, although adherence to best practices in transparency and data management is still recommended.
The majority of AI applications in the financial sector may fall into this category, offering a wide range of opportunities for automation and efficiency without the heavy compliance burden associated with higher-risk categories.
Under the EU AI Act, financial institutions need to actively assess the risk levels of their AI applications and take the right steps to stay compliant. Institutions must:
Continuously evaluate AI systems to determine their risk classification and ensure compliance with the latest regulatory standards.
Establish dedicated teams and frameworks for AI governance, focusing on transparency, accountability, and risk management.
Despite the push towards automation, maintaining human oversight is critical, particularly for high-risk AI applications.
As AI technology evolves, so too will the regulatory landscape. Institutions must remain agile, adapting to new regulations and technological advancements to maintain compliance and competitive advantage.
The EU AI Act marks an important move towards ensuring the responsible use of AI in the financial sector. By understanding and following the risk classifications and regulatory requirements, financial institutions can effectively use AI while protecting their operations and reputations in this increasingly regulated environment. In our next article, we will dive deeper into an essential aspect of managing AI - AI governance. This discussion will be crucial for understanding how to effectively manage AI systems throughout their lifecycle, from development and deployment to monitoring and continuous improvement.
Best regards,
Oleksandra Karpeko
With this article, our Associate Consultant Oleksandra Karpeko begins a series of posts discussing the AI Act in finance, exploring its implications and the compliance requirements that banks and financial institutions must meet.
Our Associate Consultant Oleksandra Karpeko continues her series on AI in finance, presenting case studies on how top banks apply AI in their operations.
Our Associate Consultant Oleksandra Karpeko continues her series on AI in finance, examining the recent surge in AI investments and acquisitions among global financial institutions.
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