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EU AI Act for real estate and proptech

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

Where this sector lands

Real estate is not an Annex III heading, but several of its workflows land in one:

• Mortgages. Evaluating the creditworthiness of an individual borrower is high-risk under point 5(b).
• Tenant screening. A model that scores a prospective tenant's ability to pay is close to the same wording. Whether a rent-affordability score counts as a creditworthiness evaluation is a question to settle with counsel, not to assume away.
• Social housing. Where a public authority, or someone on its behalf, uses AI to decide eligibility for housing assistance, point 5(a) applies.
• Valuation models that price a property, not a person, are not listed.

On the marketing side, Article 50 applies from 2 August 2026: listing chatbots must disclose they are AI, and virtually staged or AI-altered photos of a real property that would falsely appear authentic are deepfakes the deployer must disclose.

The logging duties that follow

For the high-risk parts:

• Art. 12 (providers): the screening or mortgage system automatically records events.
• Art. 19 (providers): keep those logs for at least six months.
• Art. 26 (deployers), the lender, agency or landlord: competent human oversight (Art. 26(2)), logs kept for at least six months (Art. 26(6)), and informing applicants that a high-risk system is used in decisions about them (Art. 26(11)). Deployers of 5(b) systems also carry out a fundamental rights impact assessment.

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

What counts as evidence

A rejected tenant alleging discrimination will ask what the screening tool looked at. Record the inputs by reference, the score, and the agent's or landlord's decision.

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

{"seq":1,"type":"tool.call","data":{"name":"verify_income","input":{"applicant":"ten_3380","listing":"LST-10-2291","docs":2}}}
{"seq":2,"type":"tool.result","data":{"name":"affordability","output":{"rent_to_income":0.41,"threshold":0.35,"result":"below"}}}
{"seq":3,"type":"policy.decision","data":{"kind":"tool.call","action":"block","hits":[{"rule":"no-auto-decline","message":"agent must review"}]}}
{"seq":4,"type":"tool.call","data":{"name":"agent_review","input":{"agent":"ag_19","decision":"accept_with_guarantor"}}}

The chain shows the threshold miss did not silently become a rejection.

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 29 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 screening or mortgage-assessment run once a person decides, and keep the attestation with the application file for the retention period.

Limits, stated plainly: the countersignature proves the log verified clean at a time, not that the screening was lawful or non-discriminatory. 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 29 USD.
• Compare approaches: vs. WORM storage, vs. signing your own logs.

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