Sustainable EU AI Act compliance for banks and insurance companies
Fincon Reply supports banks and insurance companies in efficiently integrating the requirements of the EU AI Act into existing structures.
The scenario
Transformation of the financial industry: The EU AI Act fundamentally changes the approach to AI systems.
With the EU AI Act, banks and insurance companies face profound changes in their handling of AI. Applications such as automated credit decisions, fraud detection, or digital claims processing are classified as high-risk systems and are subject to strict requirements. In addition to transparency obligations, especially the traceability of decisions, robust data quality, and effective risk management are required. For many institutions, this means fundamentally realigning processes, systems, and governance structures.
The Challenge
Identify high-risk use cases and ensure regulatory compliance
With the EU AI Act, high-risk use cases (e.g., lending, fraud prevention, claims processing) must be clearly identified and classified; transparency, documentation, and audit obligations must be fully met. Since many existing processes do not provide sufficient traceability, data quality, and explainability, processes and controls need to be redesigned based on risk.
Robust governance must be established: roles clearly assigned, lifecycle management and human oversight defined, and verifiable documentation (training data, testing, monitoring) consistently maintained. The fundamental rights impact assessment (FRIA) must be methodologically sound, efficient, and comprehensible for oversight.
Along the supply chain, third-party models and (G)PAI must be contractually, technically, and organizationally integrated – including criteria for changes and re-use. Qualification programs for departments, compliance, and IT need to be established. Existing regulations (e.g., GDPR) must be consistently aligned with the new obligations, without unnecessarily hindering time-to-market and innovation.
Conclusion: The implementation effort is high; priorities must be clearly set, methods designed to be scalable, and evidence maintained robustly.
The implementation
Governance and processes
modeling according to the EU AI Act
A central component of our approach is the development of a governance framework in which responsibilities, roles, and processes are clearly established, defined, and modeled – with the aim of effectively implementing requirements from the EU AI Act:
Governance & Scope
Establish a governance framework: capture AI use cases, classify according to the EU AI Act (prohibited, high-risk, limited/minimal, GPAI), define decision-making processes, delineate prohibitions, and set criteria for third-party models/supply chains.
Integrate compliance
Anchor transparency, documentation, and security requirements in IT, data management, risk, and internal control systems; implement data/model maps, test/monitoring regimes, and comprehensive evidence, consistent with GDPR and internal policies.
GRFA efficient
Set up the GRFA process: define triggers and responsibilities, use templates, assess risks, derive protective measures, integrate with DSFA, and document results in a verifiable manner.
Roles & Lifestyle
Clarify roles along the AI lifecycle (provider/supplier/operator), fix RACI and define change mechanisms, handle material changes, rebranding, or purpose changes as roles.
Monitoring & Operations
Establishing monitoring with KPIs and audits, embedding incident/crisis management and training, considering regulatory updates and supplier governance, as well as ensuring clear communication and robust audit trails.
With Fincon Reply, the EU AI Act is not a hurdle, but a competitive advantage for sustainable AI usage.
)
)
The solution
Systematic implementation of regulatory obligations
The approach model efficiently and future-proofly integrates the requirements of the EU AI Act into existing structures. Relevant questions – scope, risk classification, as well as transparency and documentation obligations – should be systematically addressed early on and represented in clear processes, roles, and documentation. The model should be designed to be scalable and auditable, and continuously adapted to regulatory updates and organizational changes.adapt.
The result
From Governance to Monitoring
The result is a compliant implementation, as the requirements of the EU AI Act are systematically integrated into existing structures. Responsibilities are transparent because roles and processes are clarified and documented early on. The use of AI is trustworthy based on a structured risk assessment – particularly the fundamental rights impact assessment (FRIA).
Efficiency gains arise from linking to existing data protection and other compliance processes. Governance processes are anchored within a continuous improvement cycle (PDCA) and are continuously reviewed and developed.
,allowExpansion)
Fincon Reply is a business and IT consultancy specializing in the financial services industry. Fincon Reply proactively advises banks, the Sparkassen Financial Group, the German Cooperative Financial Group and insurance companies as well as their suppliers on their digital transformation. The company provides on-site support with specialised teams of consultants and developers and delivers turnkey solutions.