European Union · AI Act and DORA
DORA already requires a register of every ICT third-party service and audit rights in the contracts behind them. The AI Act, as amended in July 2026, applies its high-risk duties to credit and insurance uses from 2 December 2027. The AI Use Assessment extends one register to answer both.
What applies
The texts below are the EU's. What each requires of your institution is for your counsel to grade.
| Instrument | What it asks | What it means for evidence |
|---|---|---|
| AI Act (Regulation 2024/1689), as amended by the Digital Omnibus (Regulation 2026/1744) | Annex III high-risk uses, including creditworthiness assessment of individuals and risk assessment and pricing in life and health insurance, apply from 2 December 2027. Deployers use them as instructed, with human oversight, monitoring and kept logs; credit and insurance deployers carry out a fundamental rights impact assessment. | A register of high-risk uses, including those inside providers, with oversight and log evidence for each. |
| AI Act transparency duties (Article 50) | Applied since 2 August 2026. Generative systems already on the market before then have until 2 December 2026 to add machine-readable marking. | A record of where generative AI faces customers. |
| DORA (Regulation 2022/2554), applied since 17 January 2025 | A register of information covering every ICT third-party service and its sub-outsourcing. Article 30 contract terms, including access, inspection and audit rights for you and your supervisor. | The register extended into the AI inside each ICT provider, and audit rights that reach it. |
| Supervision | National authorities remain competent for financial institutions under the amended AI Act. | Your existing supervisor is the one who will ask. |
The seven questions, in EU terms
"No reasonable reach" is a documented conclusion, not a gap. The determination at each step is yours and your counsel's.
One register, two duties
Duty 1 · DORA
Each ICT service already on your register gains the AI inside it: the model, the platform behind it, the authority delegated, and the evidence obtainable at that boundary.
Duty 2 · AI Act
The same entries mark which uses fall in Annex III, and what oversight, monitoring and log evidence exists for each before 2 December 2027.
Who it is for
Creditworthiness models are an Annex III high-risk use.
Life and health insurance risk assessment and pricing are Annex III high-risk uses.
DORA's register and contract terms apply to their ICT providers.
One group framework, read by each supervisor.
Several supervisors →For operators and manufacturers
High-risk AI embedded in products covered by EU product safety law applies from 2 August 2028, and the EU's machinery and product liability rules are being updated for AI. Operators and OEMs selling into the EU face the same question: what evidence can the AI inside the product produce?
For operators →Regulatory position as at 26 October 2026. Not legal advice: every legal determination is yours and your counsel's.
This page summarises published texts for orientation. Your counsel grades what is a requirement and what is an expectation for your institution.