# A European Bank Just Asked Whether Your AI Fraud Detection Tool Is Registered in the EU AI Act Database: Answering the Article 60 Registration Questions

# A European Bank Just Asked Whether Your AI Fraud Detection Tool Is Registered in the EU AI Act Database: Answering the Article 60 Registration Questions

The question came from a compliance officer at a Dutch retail bank. Your fintech company had been selling AI-powered transaction fraud detection to European financial institutions for two years. No customer had ever asked this before. Now one did:

> *"We require confirmation that your AI system is listed in the EU AI Act database under Article 60. If it is not yet registered, please provide a registration timeline and the relevant fields that will be submitted. This is required before we can proceed to contract."*

You had heard of the EU AI Act database. You did not know it was a procurement requirement.

It is. Here is what Article 60 requires and how to answer.

## What the EU AI Act Database Is

Article 60 of the EU AI Act establishes a public EU-wide database of high-risk AI systems. The database is operated by the European Commission and is publicly searchable. Providers of high-risk AI systems are required to register their systems in the database before placing them on the market in the EU or putting them into service.

For a fraud detection AI system in financial services, classification as high-risk is highly likely. Annex III Category 5 covers AI systems used in the areas of administration of justice and democratic processes — but more directly, an AI system that makes or informs decisions about financial transactions affecting individuals may fall under Annex III Category 5(b) or be captured under the broader risk-based provisions.

The practical question is not whether the database exists. It does. The question is: are you in it?

## What Article 60 Registration Requires

To register your system, you provide the following information in the EU AI Act database:

**Provider identity**: Your company name, registration number, and contact point for the purposes of the regulation.

**System name and version**: The specific system being registered, including version number. If you release material updates, you may need to re-register or file an update.

**Intended purpose**: A description of what the system does — in this case, fraud detection — and the specific deployment context (transaction screening, account takeover detection, and so on).

**General description of the system**: A non-technical overview of how the system operates, what inputs it uses, and what outputs it produces.

**Conformity assessment information**: Whether the system underwent a third-party conformity assessment or a provider self-assessment under Article 43, and the reference number of the certificate (if applicable).

**EU Declaration of Conformity**: A reference to your Declaration of Conformity under Article 47.

**Status**: Whether the system is on the market, in service, or withdrawn.

The database entry is not a technical deep-dive. It is a public-facing registration record. Think of it as the equivalent of a company registration — a public declaration that this system exists, who made it, and that the maker has assessed it against EU AI Act requirements.

## How to Answer the Bank's Question

The bank's compliance officer needs three things:

**First**: Confirmation of whether you are registered. If you are, provide your database entry reference number and a link to the public record. The database is searchable by provider name and system name.

**Second**: If you are not yet registered, a clear explanation of why (for example: the registration obligation applies from the date enforcement begins for your system category, and you are currently completing the conformity assessment documentation that is a prerequisite to registration) and a realistic timeline.

**Third**: A copy of your EU Declaration of Conformity (Article 47). This is the document that certifies your system meets EU AI Act requirements. It is a precondition to registration and is typically what procurement teams actually need to file.

Many fintech vendors at this stage are mid-process: they have completed risk classification and are working through technical documentation and conformity assessment, but are not yet registered. That is a defensible position — provided you can show the documentation trail and give a credible timeline.

What is not defensible: not knowing whether registration applies to your system, or not having started the process.

## The Deeper Commercial Point

Article 60 registration is becoming a sales requirement in European financial services procurement — not because regulators are demanding it at the point of sale, but because compliance teams at banks are adding it to vendor checklists. A bank that deploys an unregistered high-risk AI system takes on its own regulatory exposure.

This means your registration status is now a competitive differentiator. Vendors who are registered close faster with risk-aware buyers. Vendors who cannot answer the Article 60 question lose deals at legal sign-off.

The earlier you register — or the further along your documentation process is — the fewer deals you lose to this question.

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