DICRI Contribution to the European Commission Consultation on High-Risk AI Systems under the AI Act
The Digital Informal Credit Research Initiative (DICRI) has submitted a contribution to the European Commission consultation on the Draft Guidelines concerning the classification of high-risk AI systems under Article 6 of the AI Act.
The contribution focuses on an interpretive question that remains insufficiently clarified in the current draft Guidelines: under what conditions certain AI systems used in debt collection, restructuring, servicing, and post-default consumer-credit governance may fall within the logic of Annex III, point 5(b), particularly where such systems perform profiling, behavioural prediction, or evaluative functions capable of shaping consequential treatment affecting consumers in financial distress.
The contribution also examines the relevance of intended purpose, integrated systems, profiling, and anti-circumvention principles in increasingly interconnected digital consumer-credit infrastructures extending across origination, servicing, restructuring, and enforcement.
Alongside the consultation contribution, DICRI is publishing an expanded policy paper developing the analytical framework underlying these observations. A revised academic working paper and additional policy-oriented commentary developing these issues further are currently in preparation.
The contribution and accompanying policy paper were prepared by Catalin Gabriel Stanescu, Founder and Director of DICRI.
