Implementation Roadmap

Months 1-3: Assessment and Foundation

• Complete AI model audit identifying explainability gaps, bias risks, and EU AI Act compliance requirements
• Map current data sources and identify alternative data opportunities
• Conduct legal review of regulatory changes taking effect in 2026
• Assess technology infrastructure for API readiness and scalability constraints
• Define key performance indicators for financial inclusion initiatives

Months 4-9: Pilot and Build

• Launch explainable AI pilot programs with select product lines
• Integrate 2-3 alternative data sources and test predictive value
• Develop or acquire one green finance product offering
• Execute partnership agreements with data providers or technology platforms
• Begin small-scale pilots with underserved borrower segments
• Establish model governance committee and fairness audit processes

Months 10-12: Scale and Institutionalize

• Roll out API-based infrastructure across core functions
• Scale proven alternative data models to production
• Expand financial inclusion products based on pilot learnings
• Implement ongoing model monitoring and regular bias audits
• Launch green finance offerings to broader market
• Revise risk management frameworks for private credit volatility scenarios
• Conduct regulatory readiness assessment for upcoming compliance deadlines