Changes between two versions
What changed between the draft committee report and the plenary report
From · draft committee report· 14 May 2025
on impact of artificial intelligence on the financial sector
To · plenary report· 11 Nov 2025
on the impact of artificial intelligence on the financial sector
AI:What changed, in short
The report expands on AI risks and benefits, adding detail on LLM-specific risks and the need for mitigation.456 It introduces new sections on supervisory challenges, third-party dependency, and DORA, urging authorities to adapt and monitor.891012 It calls for clearer guidance, regulatory coordination, and support for innovation, including sandboxes and skills development.111415 It adds investment figures and a request for an ambitious venture capital proposal to boost AI innovation.13 Other changes are formal: updated references and forwarding instructions.1216
12 changes of substance · 3 formal · 1 of wording only
Written by AI from the two texts only · read the changes before relying on it · 4 Sept 2026 · Report a problem
Changes to the text itself, in document order. Cover page, citations and punctuation-only edits are left out; they are under “Every difference”.
Changes of substance · 12
Change 3 Substance
AI summary:Adds a new recital defining a general-purpose AI model, including its characteristics and exclusions.
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Added:D. whereas a general-purpose AI (GPAI) model is defined as an AI model, including those trained with a large amount of data using self-supervision at scale, that displays significant generality and is capable of competently performing a wide range of distinct tasks regardless of the way the model is placed on the market and that can be integrated into a variety of downstream systems or applications, but not including AI models that are used for research, development or prototyping activities before they are placed on the market;
Change 4 Substance
AI summary:Rewrites paragraph 1 to describe financial institutions' gradual adoption of AI, including generative AI and large language models, and notes the prevalence of high-risk credit scoring use.
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Changed:1. Notes the broad and diverse adoption of AI across the EU financial services sector, with financial institutions, which have been using classical machine learning infor long-standingan extended period, now gradually experimenting with the use andof generative AIAI, increasinglyincluding appliedlarge language models (LLMs) and other foundation models, as a support tool; stresses that the majority of current AI use cases aim to streamline back-office processesprocesses, with most applications representing low-hanging fruit rather than high-risk innovationinnovation; notes, however, that the use of AI to evaluate the creditworthiness of natural persons or establish their credit score, currently defined as high-risk in the AI Act, is prevalent and onlyincreasing; astresses limitedthat numberthe beingdeployment customer-facingof fully autonomous AI systems in the financial sector should have human oversight15; notes that financial institutions continue to explore use cases involving GPAI models, the greater complexity of which entails higher operational and nocompliance autopilotrisk, cases;but also notes that these applications largely remain in the testing phase;
Change 5 Substance
AI summary:Rewrites paragraph 2 to emphasize AI as a major opportunity, lists more benefits, and stresses balancing innovation with risk management and passing benefits to customers.
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Changed:2. HighlightsBelieves that AI is a major opportunity for EU financial institutions to develop more innovative products, streamline operations and improve competitiveness on a global scale; highlights that the use of AI in financial services canhas the potential to bring societal benefits, including more effective fraud detection,detection and prevention, anti-money laundering checks and sanctions checks, customer support, transaction monitoring, sanctionspersonalised screening,financial claimsadvice, handling,environmental, personalisedsocial financialand advice,governance creditdata riskgathering, assessment,analysis and reporting, trading models and strategies, regulatory compliance assistance, customermarket on-boardingsurveillance and identityabuse verification,monitoring; marketconsiders surveillancethat the use of AI in the financial sector should strike a balance between innovation and marketcompetitiveness abuseon monitoring;the one hand, and risk management, consumer protection and financial stability on the other hand; stresses that the benefits of AI use in financial services should be passed on primarily to end customers, for example through lower prices, better coverage, improved financial advice, greater financial inclusion and access, and enhanced financial literacy;
Change 6 Substance
AI summary:Replaces paragraph 3 with a more detailed account of risks, distinguishing pre-LLM and LLM-specific risks, and adds emphasis on mitigation.
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Removed:3. Notes that the main risks linked to the use of AI in financial services stem from the quality, accuracy and representativeness of the data on which models are trained, and from the need to ensure robust data governance, prevent discriminatory outcomes and avoid systemic biases; observes challenges related to cybersecurity vulnerabilities and to the explainability of AI systems;
Added:3. Notes that there are also risks from the use of AI in financial services; highlights that, prior to the recent breakthrough of LLMs, these risks stemmed from the quality, accuracy and representativeness of the data on which models were trained, as non-LLM AI outputs are only as reliable as the data inputs; underlines that poor data quality could lead, among other things, to discriminatory outcomes, mis-selling and reinforced systemic biases, while opaque and complex models could give rise to privacy breaches and the exclusion of vulnerable consumers through, for example, price discrimination, thereby exacerbating existing risks or creating new ones; stresses that LLMs introduce significant additional risks that can be hard to measure, including model hallucinations even where training data is of high quality; stresses that such risks and outcomes must be mitigated effectively; observes further challenges related to cybersecurity vulnerabilities and to the explainability of AI systems; stresses, therefore, the need to ensure robust data governance, rigorous testing and documentation of AI models, alongside maintaining a human in the loop and upholding a high standard for employing AI-systems in consumer-facing applications;
8 more changes of substance
Change 8 Substance
AI summary:Replaces paragraph 5 with new paragraphs 5-10 covering supervisory challenges, herd behaviour, third-party dependency, DORA, cloud infrastructure, and EU initiatives.
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Removed:5. Notes the dependency of EU financial actors on third-country technology providers for software and AI tools, which may lead to concentration risk and reduce the bargaining power of financial institutions when negotiating or modifying contractual terms for AI services; emphasises that EU companies must be able to use existing cloud infrastructure for AI development and deployment; supports, however, EU initiatives to boost AI and cloud development;
Added:5. Highlights that the rise of AI poses challenges for supervisory authorities, particularly given the lack of AI-specific expertise and adequate supervisory tools to assess advanced machine learning and generative AI models; calls on the European and national supervisory authorities to adapt to the increasing use of AI in financial services and to monitor, assess and mitigate risks to consumers and financial stability, while being mindful not to discourage innovation through disproportionate compliance burdens or overly prescriptive regulatory approaches;
Added:6. Notes that the concentration among AI service providers that offer investment advice may lead to herd behaviour, driven by similar models and limited data sources; urges the European and national supervisors to monitor these risks and financial institutions in order to account for them when developing AI tools;
Added:7. Notes the dependency of EU financial actors on third party technology providers (TPPs) to host and develop their AI models and highlights that the majority of financial firms are reliant on only a few TPPs for these services, which may lead to concentration risk and reduce the bargaining power of financial institutions when negotiating or modifying contractual terms for AI services; cautions that reliance on a small number of providers for a given service could lead to systemic risks in the event of disruptions, especially if rapid migration to alternative providers is not feasible;
Added:8. Notes that the recently enacted Digital Operational Resilience Act (DORA) requires financial institutions to implement measures to mitigate concentration risk stemming from information and communication technology (ICT) TPPs, including contingency plans and arrangements to ensure business continuity; requests that the Commission and the European supervisory authorities assess, in particular, the feasibility of applying the exit strategies and transition provisions stipulated in DORA to AI models hosted by the infrastructure of TPPs, especially with regard to the considerable reliance on third-country TPPs for AI services;
Added:9. Emphasises that EU companies must be able to use existing cloud infrastructure for AI development and deployment; calls for actively exploring avenues to strengthen the compatibility and interoperability of AI models and compliance frameworks with those of like-minded international partners, especially those that aspire to provide equally robust regulatory safeguards, to ensure that EU financial institutions maintain access to AI tools and suppliers and with a view to shaping balanced global standards while safeguarding legal certainty for European businesses;
Added:10. Supports initiatives to boost AI and cloud development in the EU, especially with a view to developing AI services that are fully compliant with EU data protection and fundamental rights frameworks, while also strengthening strategic autonomy and resilience;
Change 9 Substance
AI summary:Updates paragraph 6 to add emphasis on monitoring regulatory gaps and evolving use cases, and includes a footnote reference.
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Changed:6.11. Stresses that the financial services sector is highly regulated, subject to multiple pieces of sectoral legislation at both national and EU level, requiring actors to manage risks in a variety of areas including data protection, data lineage, data quality, data governance, operational resilience, outsourcing, model risk, discriminatory outcomes, and market and credit risk, which together form the framework for AI deployment and governance in the financial services sector;sector16; emphasises, however, the importance of continuously monitoring regulatory gaps and evolving use cases of AI in finance, especially with a view to safeguarding consumer rights and the right to privacy;
Change 10 Substance
AI summary:Replaces paragraph 7 with a new paragraph 12 noting the EU's risk-based approach and the AI Act's incomplete implementation.
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Removed:7. Expresses concern about regulatory overlaps and legal uncertainties between the AI Act and sectoral legislation;
Added:12. Notes that the EU has adopted a more risk-based approach to AI regulation than other jurisdictions; underlines that, while this may create challenges for the adoption and development of AI in financial services, it also offers an opportunity to build trust and support innovation, provided that the framework is clarified and implemented in a way that fosters legal certainty, proportionality and market confidence; recognises that the AI Act has not yet been fully implemented and that its practical implications have not yet been assessed;
Change 11 Substance
AI summary:Rewrites paragraph 8 to detail the AI Act's derogations, express concern about overlaps, and request the Commission to address inconsistencies.
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Changed:8.13. Recalls that the AI Act allowsexplicitly takes into account the current financial services acquis and seeks to avoid duplication of requirements, particularly with regard to internal governance and quality management processes, by allowing for limited derogations for financial institutions wherein so far as equivalent requirements existare underlaid down in EU financial services law; expresses concern aboutthat thethere are, nonetheless, regulatory overlaps and a lack of sufficient guidance on the interpretation of these regulatory overlaps and interactions;interactions, cautionswhich againstintroduces adoptingundue complexity, compliance burdens and legal uncertainty, thus hindering the uptake of AI in the financial services sector; underlines the importance of guaranteeing a maximalistlegal, approachregulatory toand administrative framework that is based on certainty, predictability and stability; notes that an expansive interpretation of the AI Act, whichrather wouldthan furthera complicateproportional one, may risk leading to undue compliance requirements for financial institutions;institutions and causing legal uncertainty; recognises the challenge arising from the fact that supervisory agencies have differing legal interpretations and expectations in terms of the application of the acquis, resulting in fragmentation of the single market; asks the Commission and the national competent authorities to identify and address any inconsistencies in the course of the AI Act’s implementation and as part of the upcoming Digital Omnibus package;
Change 12 Substance
AI summary:Replaces paragraph 9 with new paragraphs 14-16 on supervisory designation, coordination, and GDPR limitations.
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Removed:9. Expresses concern that the GDPR and its requirements on data minimisation, purpose limitation, customer consent, and financial institutions’ processing of personal data impose limitations to the use of AI in financial services;
Added:14. Supports the AI Act’s recommendation to designate financial competent authorities as market surveillance bodies for AI systems used in financial services deemed high-risk; notes, however, that other national competent authorities will be responsible for supervising non-high-risk AI systems; recognises the challenges arising from having multiple supervisory agencies with competences regarding the application of the acquis; recognises, furthermore, the challenges arising from the differing legal interpretations and expectations of the various supervisory agencies, which could lead to the fragmentation of the single market;
Added:15. Encourages the supervisory authorities to strengthen coordination, cooperation and information exchange to avoid overlapping jurisdiction claims; urges, moreover, the Commission and the supervisory authorities to strengthen cooperation with international partners in global standard-setting forums to ensure alignment and avoid the fragmentation of regulatory approaches, as well as to ensure that the EU keeps pace and aligns with global regulatory developments;
Added:16. Notes that the General Data Protection Regulation and its requirements on data minimisation, purpose limitation, customer consent, and financial institutions’ processing of personal data impose limitations on the use of AI in financial services; considers that the right balance is needed between reaping the benefits of the use of AI in financial services and the protection of consumers’ data;
Change 13 Substance
AI summary:Updates paragraph 10 to add investment figures and a call for an ambitious venture capital proposal.
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Changed:10.17. Regrets that the EU is lagging behind in terms of AI innovation and investment;investment, as illustrated by the EUR 33 billion in venture funding received by EU companies developing foundational models between 2018 and 2023, compared to over EUR 120 billion received by their US counterparts17; believes that the financial services sector, as the largest spender on ICT services and products, has the potential to act as a catalyst in mobilising private investment in AI; calls, against the backdrop of slow AI investment in the EU’s financial sector, for an ambitious proposal to jump-start the European venture capital scene as part of the savings and investments union;
Change 14 Substance
AI summary:Rewrites paragraph 11 to call for clear practical guidance and cautions against one-size-fits-all approaches.
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Changed:11.18. Calls on the Commission to ensureprovide clarityclear and guidancepractical guidance, developed in consultation with the European and national supervisory authorities and stakeholders, on howthe application of existing financial services regulationslegislation applywith regard to the use of AI in financial services;AI; considers that such guidance should aim to enable the use of AI in the financial services sector;sector, including in a way that is ethical, responsible and transparent; calls for consistent definitions and the simplification of the regulatory framework to avoid duplicated requirements, including risk assessment reporting requirements;requirements, and cautions against a one-size-fits-all approach that places a disproportionate burden on smaller and medium-sized financial institutions; emphasises the need for a good balance between the responsible use of AI and providing enough room for innovation;
Change 15 Substance
AI summary:Replaces paragraphs 12-14 with new paragraphs 19-25 covering AI-driven tools, sectoral legislation, supervisory support, entry barriers, environmental impact, skills, and sandboxes.
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Removed:12. Warns against the adoption of new sectoral legislation to regulate AI in financial services, as there are already established sectoral rules that cover AI deployment; believes that this would create additional layers of complexity and uncertainty and ultimately deprive the sector of the benefits of AI use; strongly advises the Commission and the Member States to coordinate to avoid gold-plating relevant legislation and to prevent the creation of new barriers in cross-border markets;
Added:19. Calls on the Commission to explore how AI-driven tools can be used in financial markets, such as in intermediation, portfolio management and compliance automation, to contribute to the objectives of the savings and investments union, including by supporting retail investors in making informed investment decisions, enhancing financial education, fostering innovation among companies, reducing market fragmentation and ensuring a safe environment for consumers; stresses that achieving these goals requires a technology-neutral regulatory framework;
Removed:13. Calls on the European and national supervisory authorities to support the uptake of AI by promoting consistent interpretations and avoiding overly strict application of existing regulations; believes that failure to support the uptake of AI risks depriving the financial services sector of the benefits of AI; emphasises that the attitude and approach of supervisors are as important as the rules themselves; recommends that supervisory efforts prioritise tangible, operational risks where identified, rather than abstract or theoretical concerns;
Added:20. Believes that sectoral legislation regulating the use of AI in financial services is mainly sufficient to cover AI deployment in its current form; underlines that there should be continuous monitoring to determine if there are duplications or deficiencies in the current financial services legislation applicable to AI deployment; underlines that additional legislation would add complexity and uncertainty and ultimately risk depriving the sector of the benefits of AI use; stresses that reliance on current frameworks requires continuous supervisory attention, effective enforcement and clear allocation of responsibility for ensuring compliance, particularly in cross-border or outsourced AI deployment scenarios, as well as the monitoring and assessment of possible future gaps created by new AI developments if they create substantial risks to consumers and financial stability; strongly advises the Commission and the Member States to coordinate to avoid gold-plating relevant legislation and to prevent the creation of new barriers in cross-border markets; notes that the Commission, according to the AI Act, can assess the list of high-risk applications under Annex III to the AI Act;
Removed:14. Believes that significant changes in the use of AI will require appropriate skills and talent, considering that the use of AI is dependent on human capabilities; supports industry measures to improve the understanding and responsible use of AI technology in the sector; asks for more clarity with regard to the AI Act’s requirements for financial institutions to comply with AI literacy requirements;
Added:21. Calls on the European and national supervisory authorities to support the responsible uptake of AI by promoting consistent interpretations and proportionate application of current regulations; believes that adequate regulation of AI deployment in the financial services sector supports uptake and societal trust in AI; emphasises that the attitude and approach of supervisors are as important as the rules themselves; recommends that supervisory efforts prioritise tangible, operational risks where identified, rather than abstract or theoretical concerns, while maintaining an active and proportionate approach to supervision, by balancing innovation and consumer protection, to manage unforeseen risks arising from the widening uptake of AI technologies; stresses the role of effectively monitoring and addressing AI-related risks, including those related to opacity, market concentration and loss of accountability, which could impact financial stability;
Added:22. Calls on the Commission and the Member States to remove entry barriers within the EU for AI-driven innovative financial undertakings, including through streamlined licensing, cross border scale-ups and inclusion in supervisory innovation hubs;
Added:23. Supports research into the environmental impact of AI use, with a focus on resource intensity and long-term sustainability, in order to increase transparency and help financial institutions to assess these aspects and their own environmental footprint;
Added:24. Believes that the increasing use of AI, which may have implications for the financial services job market, requires strong AI literacy, digital skills, and talent involvement, supported by both public-sector upskilling initiatives and market-based solutions; supports industry efforts and targeted initiatives, including public-private partnerships and reskilling programmes, to build technical and ethical AI competencies, especially regarding rights and risks, in the financial workforce; underlines the importance of developing AI strategies that enhance productivity, while supporting workers’ adaptation, upskilling and reallocation, while ensuring meaningful human oversight and control; asks for more clarity with regard to the AI Act’s requirements for financial institutions to comply with AI literacy requirements; stresses, furthermore, the importance of ensuring and promoting equal access to AI tools and services, including for less digitally capable segments of the population;
Added:25. Calls on the Commission and the European and national supervisory authorities to assess the added value of AI-specific regulatory sandboxes, innovation hubs and cross-border testing environments for financial services in enabling experimentation with AI-driven financial innovation, both to help start-ups test their products and to allow incumbent institutions to explore new use in a controlled setting, while safeguarding consumer protection and market integrity; believes that properly leveraging AI regulatory sandboxes could provide the structured, supervised testing environment necessary to facilitate innovation and responsible AI deployment within the financial services sector; encourages the European and national supervisory authorities to enhance supervisory tools and technology (SupTech) through the use of AI and integrate them into daily supervisory activities to improve the efficiency and effectiveness of financial supervision; notes that these tools are intended to support, not replace, human supervisors;
3 formal changes: legal basis, citations, references, corrections
Change 1 Formal
AI summary:Adds the acronym "AI Act" after the first mention of the Artificial Intelligence Act.
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Changed:A. whereas the EU Artificial Intelligence Act (AI Act) introduces the world’s first comprehensive regulatory framework for artificial intelligence (AI);
Change 2 Formal
AI summary:Updates the reference to the AI Act by specifying points 5(b) and (c) of Annex III and adjusts the verb accordingly.
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Changed:B. whereas points 5(b) and (c) of Annex III to the AI Act definesdefine two high-risk use cases for the financial services sector, namely the use of AI systems for consumer credit scoring and creditworthiness assessments and their use for risk assessments and pricing of life and health insurance;
Change 16 Formal
AI summary:Updates the forwarding instruction to include the Commission and member state governments and parliaments.
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Changed:15.26. Instructs its President to forward this resolution to the CouncilCouncil, the Commission and the Commission.governments and parliaments of the Member States.
1 change of wording only
Change 7 Wording
AI summary:Changes "prudent and gradual" to "measured" and adds a reference to risks outlined above.
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Changed:4. Understands that financial institutions have adopted a prudent and gradualmeasured approach to developingdeveloping, testing and deploying AI systems, with a view to ensuring compliance with existing cross-cutting and sectoral legislation; underlines that this prudent approach may also be driven by undemonstrated customer demand, evolving customer expectations and risk considerations;considerations, which have been outlined above;