Skip to content

Applied AI

AI in payments, credit and fraud under the EU AI Act

AI in payments and credit covers the models that score creditworthiness, price risk, detect fraud, monitor transactions and automate customer service in financial firms. Under the EU AI Act, creditworthiness assessment of natural persons and life and health insurance pricing are high-risk uses, with obligations on both the provider of the model and the firm that deploys it; fraud detection is expressly carved out of that tier but still sits under financial regulation and model risk expectations. Hexploits builds these systems with the documentation, logging, human oversight and testing the Act and the FCA expect, from the first release.

A named engineer replies within one working day. A written scope and an indicative price within two.

  • Lenders and BNPL providers using models in credit decisions for individuals.
  • Payment firms and acquirers running fraud, chargeback and transaction-monitoring models.
  • Insurers pricing life or health cover with models.
  • Model risk and compliance functions asked to approve AI they did not build.

Deliverables, not slogans. Each one appears in the statement of work.

  • Risk classification of every AI use in the payment, credit and servicing flows, with the reasoning written down.
  • For high-risk uses: risk management records, technical documentation, automatic logging, human-oversight procedures and a post-market monitoring plan.
  • Fundamental Rights Impact Assessment support for credit-scoring and insurance-pricing deployers where Article 27 requires it.
  • Bias and performance testing against your own portfolio data, refreshed on a schedule, with results on file.
  • Explanations for adverse decisions that a customer and a complaints handler can both use.
  • Fraud and transaction-monitoring models with the false-positive rate, review queue and audit trail measured and reported.

Our engineers work across the major languages, frameworks and cloud platforms. We build on the stack you already run, with technology choices explained in writing before work begins.

The same four stages as every Hexploits engagement, applied to this capability.

  1. Stage 1

    Inventory and classify

    Two to four weeks. Every model in the flow is listed, its use mapped to the Act’s categories, and provider or deployer status determined. Output: a dated plan to each deadline and a fixed figure or capped estimate.

  2. Stage 2

    Build the controls

    Logging, oversight, testing and documentation are built into the model pipeline and the release process, so evidence is produced by the system rather than assembled before an audit.

  3. Stage 3

    Launch

    Shadow-mode running against the existing decision process, bias and performance results reviewed with model risk, then cutover by segment.

  4. Stage 4

    Monitor

    Drift, bias and performance monitoring, incident handling and periodic review under deployment and monitoring, with the inventory kept current.

We are the core engineering team behind swarmd.ai

swarmd.ai is an EU AI Act readiness platform for governing AI agents in highly regulated industries: policy enforced on every action, tamper-evident audit trails, per-tenant isolation and customer-owned identity. The same patterns are what we apply to a lender’s or a payment firm’s own models.

Every engagement agrees its measures and the measurement period in writing before work starts.

  • Every model classified, with documentation complete before its applicable deadline.
  • Bias and performance test results on file and refreshed on schedule.
  • Fraud model precision and recall, and the review queue size, reported monthly.
  • Adverse decisions with an explanation available, as a share of all adverse decisions.

Case studies with numbers, and reviews linked to Google where they were left there.

  • Director, IO Solutions

    Fantastic to work with. High level of attention to detail and flawless communication throughout. Would recommend to anyone looking to develop or improve a software product.

    Christian LorzaDirector, IO SolutionsRead the review
  • Director, JobVantage

    Working with Hexploits has genuinely been a pleasure, and I see them as my scaling partner for the foreseeable future as JobVantage grows. If you’re looking for a development team who combine strong AI/engineering capability with honesty, flexibility and a real interest in your business, I’d strongly recommend them.

    Brandon BowdenDirector, JobVantageRead the review
Is credit scoring high-risk under the EU AI Act?
Yes. Annex III lists AI used to evaluate the creditworthiness of natural persons or establish their credit score as high-risk, except where used to detect financial fraud. Life and health insurance risk assessment and pricing are also listed. Deployers of these systems must complete a Fundamental Rights Impact Assessment before first use.
Is fraud detection high-risk?
No. AI used to detect financial fraud is expressly excluded from the credit-scoring high-risk category. It still sits under financial regulation, model risk expectations and data protection law, and it still needs the testing and audit trail a regulator will ask for.
When do the obligations apply?
Following the Digital Omnibus, standalone high-risk systems under Annex III, which include credit scoring and insurance pricing, must comply by 2 December 2027. Prohibited practices have applied since February 2025. A UK firm is in scope where the system’s output is used in the EU or it lends to or insures EU customers.
Does this replace our model risk framework?
No. It produces the documentation, testing and monitoring your model risk framework and the Act both ask for, from the same pipeline, so the evidence is created once and used for both.
Is this legal advice?
No. We do the engineering and operational side of readiness and work alongside your legal counsel and compliance function, who sign off the regulatory position.

Request a proposal.

Tell us about the system and the sector. A named engineer replies within one working day. A written scope and an indicative price within two working days of a short scoping call.