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Home/Regulation Tracker/CJEU SCHUFA Holding (C-634/21) — credit scoring as an automated decision

CJEU SCHUFA Holding (C-634/21) — credit scoring as an automated decision

The EU's highest court held that credit scores are automated decisions in their own right when lenders rely on them, extending Article 22 GDPR to scoring providers and, in 2025, spelling out the explanation that must follow.

cjeuschufacredit scoringarticle 22

Required actions

  • Producing a probability score that a third party draws strongly on to decide a contract is itself a decision based solely on automated processing under Article 22 - Scorers must therefore meet Article 22 conditions and provide meaningful information about the logic; the 2025 Dun & Bradstreet ruling requires explanations comprehensible to the data subject

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