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EU AI Act for benefits agencies

*Engineering guidance, not legal advice. Your legal team decides how the Act applies to your products.*

Where this sector lands

Annex III point 5(a) covers AI systems intended to be used by or on behalf of public authorities to evaluate the eligibility of natural persons for essential public assistance benefits and services, including healthcare, and to grant, reduce, revoke or reclaim them. Unemployment, disability, housing and family benefits all fit. The govtech page covers public services more broadly; this one is for the agencies paying benefits.

Two points specific to benefits:

• Fraud and overpayment models are not exempt. The fraud-detection exception in Annex III applies to credit scoring in point 5(b), not to benefits. A model that flags claimants for reclaim is deciding to reduce or reclaim.
• Social scoring is prohibited. Article 5(1)(c), in force since 2 February 2025, bans scoring people on their social behaviour or personal characteristics where the score leads to unjustified or disproportionate detrimental treatment, or treatment in unrelated contexts.

The logging duties that follow

• Art. 12 (providers): automatic recording of events so each eligibility or reclaim decision can be traced.
• Art. 19 (providers): keep logs under your control for at least six months.
• Art. 26 (deployers), the agency: competent human oversight (Art. 26(2)), logs kept for at least six months (Art. 26(6)), use only of systems registered in the EU database (Art. 26(8)), and informing claimants that a high-risk system is used in decisions about them (Art. 26(11)). A fundamental rights impact assessment is required before first use.

Claimants can ask for an explanation of the system's role in a decision (Art. 86).

On timing: the Digital Omnibus agreement moves Annex III high-risk obligations to December 2027 (details and caveats).

What counts as evidence

Reclaim decisions are appealed and sometimes end up as public scandals. The agency must show, per claimant, what the model flagged, on which features, and who decided.

Abbreviated ledger excerpt (prev, hash and sig omitted):

{"seq":1,"type":"tool.call","data":{"name":"load_claim","input":{"claimant":"clm_58302","benefit":"housing_allowance"}}}
{"seq":2,"type":"tool.result","data":{"name":"overpayment_risk","output":{"score":0.81,"features":["income_change","address_change"]}}}
{"seq":3,"type":"policy.decision","data":{"kind":"tool.call","action":"block","hits":[{"rule":"no-reclaim-without-caseworker"}]}}
{"seq":4,"type":"tool.call","data":{"name":"open_review","input":{"caseworker":"cw_441","deadline_days":14}}}

The blocked automatic reclaim is the evidence that a person, not the score, made the decision.

How Vetro Attest fits

Vetro Attest accepts an OpenTelemetry GenAI trace (OTLP/JSON) or a native Vetro ledger, with nothing to install. Verification is free. For 49 USD per ledger, one-off:

• a full EU AI Act report (Markdown and HTML) mapping the run onto the logging obligations, with an explicit list of what the log cannot show;
• an ed25519 countersignature over the ledger digest, event count and timestamp, verifiable by anyone with our published public key.

A practical pattern: countersign each decision run and keep the attestation in the claimant file for the appeal period. Redact claimant data before export; the attestation itself covers only a digest.

Limits, stated plainly: the countersignature proves the log verified clean at a time, not that the eligibility decision was correct or proportionate. The report supports a compliance conversation; it is not a conformity assessment. Paid ledgers are deleted after 7 days, and the report and attestation are emailed to you to keep.

Next steps

• Run the free EU AI Act Art. 12/14 checker against your current setup.
• Verify a trace free, then get the countersigned report for 49 USD.
• Compare approaches: vs. WORM storage, vs. OpenTelemetry alone.

See a sample ledger verified in one click, check your own logs free or get the countersigned EU AI Act report.