Kovcheg's credit module drafts decisions on customer applications. Under the EU AI Act, this is not an "assistant" — it is a high-risk AI system. Creditworthiness assessment of individuals is explicitly named in Annex III, which moves the system into a different legal class: a mandatory risk management system, technical documentation, logs, human oversight, registration. In parallel, the text assistant generating replies to customers falls under Art. 50 — transparency for AI-generated content. One system, two different sets of obligations.
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