Understand what the output changes.
Map where an AI output enters a business process and whether it influences a decision about a person. Relevant Annex III examples include individual creditworthiness and certain life or health insurance uses; the creditworthiness category expressly distinguishes financial-fraud detection.
Do not apply one label to every financial-services tool. A drafting assistant, fraud investigation aid and lending decision system need separate factual descriptions and appropriate classification review.
Connect model and supplier evidence to your use.
Identify the system owner, supplier dependencies, relevant evaluations and documented limitations. Ask whether the evidence reflects the population, information and operating conditions involved in your deployment. A general performance claim may not answer the questions your reviewers need to resolve.
Link procurement, model governance and operational records where useful, while preserving their different purposes. Reviewers should be able to see which evidence supports a decision and which questions require additional work.
Make review and escalation workable.
Define when an employee reviews an output, what information they receive and how they can challenge it. Consider complaints, inconsistent outcomes and changes in behaviour as potential review inputs. Assign the authority to restrict use and communicate with the supplier when a concern emerges.
- Use-case and decision-flow descriptions.
- Supplier and evaluation evidence references.
- Oversight instructions and escalation contacts.
- Conditions of approval and change-review records.
Fit the programme to existing governance.
Financial organisations already operate important governance and control processes. An EUAIC scope should identify where AI records can connect with those processes and where additional questions need a distinct review. It should not create duplicate approval steps without a clear purpose.
Start with a bounded business function and its accountable owners. Applicable financial, privacy and AI requirements need to be assessed together by the appropriate advisers; a governance application does not provide regulatory authorisation.