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What the EU AI Act means for collections

Written by Martin Germanis | Sep 10, 2025 5:15:00 PM

The European Union’s landmark legislation, the EU Artificial Intelligence (AI) Act, represents a major shift in how artificial intelligence will be governed across different sectors. 

For financial institutions and organizations involved in collections, this regulation requires action rather than awareness. As AI becomes more deeply embedded in everything from risk scoring to personalized collections strategies, the EU AI Act raises essential questions about transparency, fairness and accountability.

What does this mean for the collections industry and how can technology providers and financial businesses stay ahead?

The EU AI Act

The EU AI Act is the world’s first comprehensive legal framework governing artificial intelligence. It was developed in response to growing concerns about the ethical use of AI and aims to balance innovation with fundamental rights protections. The intention of the legislation is to build public trust in AI and ensure the responsible deployment of intelligent systems across society. 

At the heart of the regulation is a risk based framework, which classifies AI systems into four categories based on their potential to cause harm. 

  • Unacceptable risk: These AI systems are banned outright, including using social scoring by governments
  • High risk: Systems that could significantly impact individuals’ rights or safety, including many used in financial services
  • Limited risk: Subject to transparency obligations, such as AI chatbots or recommendation engines
  • Minimal risk: No specific regulation beyond existing laws

Collections related AI, including automated decisioning tools, behavioral scoring models, and workflow optimization engines will likely fall into the high risk category due to their potential impact on individuals’ financial well-being. This classification introduces new obligations for organizations using AI in collections, including:

  • Transparency and explainability
  • Robust documentation and record-keeping
  • Human oversight
  • Regular auditing and risk assessments
  • Strict data governance and fairness checks

What this means for collections

Collections operations are no stranger to AI, increasingly relying on specialized systems to segment customers, predict repayment likelihood and personalize engagement. These tools boost recovery rates and improve customer experience simultaneously, but they also have the potential to introduce regulatory risks if not managed properly.

The EU AI Act signals a clear expectation: AI must be explainable, fair, and auditable. In the collections space, this translates to:

  • Accountability in automated treatment paths: Who decides how customers are categorized and treated? Can this be traced and explained?
  • Fairness in algorithmic decisioning: Are models unintentionally discriminating or perpetuating bias?
  • Customer transparency: Are individuals aware they’re interacting with AI? Can they request human review?

Teams need to ensure their AI performs responsibly in line with both regulatory requirements and evolving customer expectations.

The role of transparent, auditable systems in collections

As the EU AI Act pushes new expectations around traceability, fairness, and human oversight in collections, the spotlight is now on the systems themselves. It’s not enough for AI to simply drive performance, it has to also be explainable and adaptable.

This is where configurable systems and decisioning solutions become essential. Collections teams need tools that optimize engagement whilst supporting full visibility into how and why decisions are made at the same time. 

No matter if you’re assigning a treatment path or determining an outreach strategy, every action must be auditable and justifiable. Configurable solutions and decisioning systems designed for collections must offer:

  • End-to-end transparency in decision-making logic
  • Audit trails for all automated or semi-automated actions
  • Human-in-the-loop capabilities to ensure oversight where needed
  • Support for institution specific algorithms without sacrificing compliance
  • Real-time adaptability to respond to regulatory, economic, or customer behavior shifts

These capabilities meet the demands of the EU AI Act and foster trust with regulators and customers. By giving teams control over their own strategies with embedded guardrails that enforce fairness and explainability, configurable systems ensure collections remain high performing and governance ready.

Be prepared for compliance with a leading platform

The message from the EU is clear: AI must serve people safely, transparently, and fairly. In collections, this means aligning AI strategies with compliance requirements and customer needs. C&R Software’s solutions are designed for exactly this balance, helping institutions collect more in less time while remaining fully compliant.

As the regulatory landscape shifts, the collections industry must evolve with it. With tools like FitLogic and Debt Manager, financial institutions can move forward with confidence driving better outcomes through transparent AI and customer-focused strategies. 

Together, these solutions help you stay ahead of regulation to deliver exceptional customer experiences that result in enhanced performance

Get in touch via inquiries@crsoftware.com to learn how C&R Software can help you build transparent, high-performing collections strategies that align with the EU AI Act and other regulations to set you up for long term success.