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Govern · agent risk record · Finance

Credit Check Agent

depth-agent

All agents
Risk class
High risk
EU AI Act Annex III(5)(b)
Status
Operating with a gap
A3
Oversight
Ana Duarte, Group Financial Controller, as escalation
Credit manager
Explanation
On request
No reference document
Appeal path
Named human
120h service level
Conformity
Not assessed
assessed 41d ago
Declared gap

The sole-trader segment makes a commercial credit process a high-risk system for part of its population. That segment is not separated in the current configuration, so the human-review rule is applied to a broader set than strictly required and there is no fairness monitoring on it at all.

Classification

Why this agent sits in this class, under which regime

Regime
EU AI Act Annex III(5)(b)
Class
High riskAffects access to employment, credit or a comparable material interest. Requires human oversight, logging and contestability.
Basis
Creditworthiness evaluation. High risk where the counterparty is a natural person, which applies to the sole-trader segment of the customer base.
People affecting
Yes — the output changes an outcome for a named person
Scope
finance
Registered
not on the register
Log retention
84 months of decision logs retained
Conformity
Not assessedNo conformity assessment on record.

Human oversight

The measure, and the person it is attached to

Measure
Credit limit changes affecting sole traders route to a human analyst. Corporate counterparties are handled autonomously within band.
Named human
Ana Duarte, Group Financial Controller, as escalation · Credit manager
Autonomy
A3
Transparency notice
Not served
Explanation surface
On requestAn explanation is produced when the affected person asks for it.

How an affected person contests this

The route, the named human at the end of it, and the service level

0 appeals on record
Route
Credit manager, then Group Financial Controller
Path type
Named human
The appeal lands with a person, not a queue.
Service level
120 hours
No appeal currently open against this agent.
No appeal has been raised against this agent. That is an absence of appeals, not evidence that the path works.

No monitoring attached

This agent affects people and has no decision point on the fairness register

The agent is classified as people-affecting but no adverse-impact monitoring is wired to it. There is nothing to read here, and that absence is the finding.

What this record is, and what it is not

Read this before quoting anything above

Fairness readings computed on modeled data demonstrate the instrument, not a real audit result. The classification, the oversight measure, the explanation surface and the appeal route are design decisions recorded here so they can be argued with; the population behind the readings is modeled.

No agent on this register carries an independent third-party conformity assessment. Every assessment on file was made by the operator.

Appeal outcomes are recorded against the evidence spine where a unit reference exists. Where the evidence column reads “not recorded”, the appeal was resolved outside the spine and that is a gap, not a rounding.