Automated credit assessment 2026/2027 – human review, letter of explanation and rejection log | Word/PDF/Excel

Automated credit assessment – ready-made templates for human review and clear explanations for consumers. The new Consumer Credit Act (2026:1011) comes into force on 20 November 2026. Chapter 3, Section 15 contains special obligations when credit assessment involves automated processing of personal data: consumers must be informed of the right to request human review, an explanation, and information about the risks of automation. This product provides Swedish lenders with a concrete documentation workflow.

You get: five Swedish working documents, a Swedish user guide, and a separate English User Guide. All seven documents are available in both editable Word (DOCX) and searchable PDF formats, plus an Excel register (XLSX) with nine tabs: 7 Word + 7 PDF + 1 Excel = 15 files in a digital ZIP. The PDF versions are searchable and printable, but are not interactive forms. The working documents and Excel file are in Swedish.

Who needs this product?

It is designed for lenders, lending institutions, compliance, legal, customer service, and product owners responsible for automated credit assessment workflows.

• Situation 1: a customer requests that a real case officer review an automated credit assessment.
• Situation 2: a consumer loan is rejected based on actual data in an external database, and the customer needs a correct rejection notice.
• Situation 3: a company is redesigning its credit decision workflow ahead of 20 November 2026 and wants to test exceptions, information obligations, and human review.

When is the template not the right choice? If you want a general credit policy, the credit agreement itself, a creditworthiness model, a tool that calculates repayment ability, or a solution that automatically approves loans. It is also not intended for use without an individual assessment of which credit type and legal regime applies.

File by file: exact contents

Excel with nine tabs

Start, Customer Case, Credit Assessment, Request, Human Review, Explanations, Rejection, Actions, and Sources. Enter only anonymous or pseudonymous process IDs, responsible parties, secure source references, and actual status updates. The compilation shows scope and open actions.

Excel is designed to distinguish "Missing documentation" from "Documentation registered – MANUAL REVIEW". This status is not proof that a case complies with the law. No personal credit information or fictitious customer cases are included in the customer file.

What does the new Consumer Credit Act say?

1. Credit assessment: According to Chapter 3, Sections 13–14, the trader shall assess the consumer's financial circumstances based on relevant and proportionate information. The document package does not perform this assessment.

2. Human review: According to Chapter 3, Section 15, when credit assessment involves automated processing of personal data, the trader shall, at the consumer's request, review the credit assessment with human involvement, explain the significance of the automated processing, and inform about its risks. The consumer shall be informed of this possibility in connection with the credit assessment.

3. Rejection notice: According to Chapter 3, Section 16, the consumer shall be notified as soon as possible of the reason if the credit is not approved. When the rejection is based on information from an external database, special information about the data and the database shall be provided.

4. Important limitations: Chapter 3, Section 19 contains exceptions for, among others, special invoice credit. Other rules apply to certain special credits. The fact that a purchase is invoiced does not in itself mean that the exception is met. The repealed Consumer Credit Act (2010:1846) still applies to many credit agreements concluded before 20 November 2026, according to the special transitional provisions. Assess the applicability to the individual case.

GDPR and AI Act – two separate controls

GDPR Article 22: IMY describes the right not to be subject to certain decisions based solely on automated processing that produce legal or similarly significant effects. This is a different criterion from Chapter 3, Section 15 of the new Consumer Credit Act. A credit assessment may involve automated processing without the entire decision being solely automated.

EU AI Act: Annex III, point 5(b) identifies certain AI systems intended to assess natural persons' creditworthiness or establish credit scores, with an explicit exception for AI systems intended to detect financial fraud. According to Amending Regulation 2026/1744, relevant high-risk provisions will, as a starting point, apply from 2 December 2027, with special transitional rules. Not every automated credit assessment uses AI, and not all AI in the financial sector is automatically high-risk.

Six steps in a proper process

1. Check the agreement date and applicable law, credit type, exceptions, and role responsibilities.
2. Determine whether and how automated processing is used in the credit assessment.
3. Send tailored information and a readily available contact channel where the obligation applies.
4. Receive the consumer's request and assign a case officer with actual review authority.
5. Review the data and the basis of the decision, explain the significance of automation, respond to the request, and send a reasoned rejection notice in case of rejection.
6. Follow up on deviations, test the system, and document your own human operational and change decisions.

Frequently asked questions

Must a customer always receive a human review of the credit assessment?

Chapter 3, Section 15 of the new Consumer Credit Act sets special requirements when a comprehensive credit assessment involves automated processing of personal data and the consumer requests a review. Check the credit type, exceptions, and transitional rules. GDPR Article 22 may be relevant according to other criteria.

Does the law already apply on 12 November 2026?

No. The Consumer Credit Act (2026:1011) comes into force on 20 November 2026. The package helps companies prepare the processes before then. Earlier legal rules, including GDPR, may already apply.

Can we use the same notice for all credit rejections?

No. The reason for rejection, actual data, and any external database must reflect the individual assessment. The fields must be filled in and quality-assured.

Is a case officer who just presses approve sufficient?

Not as a general guarantee. The template presupposes a real opportunity for a reasoned review, a clear explanation, and documented control.

Does this also apply to regular invoice payments and BNPL?

It depends on the legal classification of the credit product, the parties involved, and special exceptions, including Chapter 3, Section 19. Do not make a decision based solely on the designation "invoice".

Does Excel perform a credit assessment or legality check?

No. It is a control and case register. No credit scores, income, debts, or personal identity numbers should be saved there.

Are the documents approved by a lawyer and is the PDF interactive?

No. Legal sources have been AI-assisted checked as of 12 November 2026, not by an independent lawyer. The PDF is searchable and printable but not digitally fillable; use Word for editing.

Related Mallbutiken products

For payment solutions in Shopify, there is BNPL – credit control in Shopify checkout and BNPL & invoice in e-commerce. These handle different steps than the consumer's request for human review. For an already incorrectly registered credit result, there is Correction of credit report.

Sources and transparency

Official sources: Consumer Credit Act (2026:1011), IMY's guidance on automated decision-making, AI Act (EU) 2024/1689, and 2026/1744. Version 1.0, reviewed 12 November 2026. The product is a documentation aid, not an official form, lending service, automatic AI certification, or individual legal opinion. Delivery is a ZIP file after separate publication and file linking.