Credit is decided by models.
From 20 November 2026, EU lenders must explain automated credit decisions and offer a human review on request. UK and UAE rules point the same way.
Phainly comes from the Greek phainō, to bring to light.
Every machine decision, brought to light.
Models already decide who gets credit. Next, AI agents will pay on your customers' behalf. Phainly explains each automated decision, proves who authorised it and keeps it within limits, so you can automate and still answer for every outcome.
EU Consumer Credit Directive applies in EU Consumer Credit Directive has applied for 15 d 10 h 04 m
Every bank now has to show its work.
For decades a person decided, and a person could explain. Now models decide in milliseconds and agents are learning to pay. Supervisors in Brussels, London and Abu Dhabi are asking banks the same question.
Customers will send agents.
Visa and Mastercard opened agentic payments to dozens of European banks in 2026. Banks still can't see who sent an agent, or what it is allowed to do.
Machines will move money.
Gartner expects AI agents to handle more than $15 trillion of business purchasing by 2028. Many spend controls for AI only send an alert.
Three products, timed to the market.
LUCID solves the problem lenders face this month. SIGIL and KEEL are built for the next wave, and we are designing them with partner banks now.
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LUCID
Explained credit decisions and human review
Every “no”, explained. Every review, real.
LUCID sits beside any scoring model. It turns each automated credit decision into a clear explanation, a path to yes, a one-tap human review and a sealed record. Those are the things CCD2 asks of lenders from 20 November 2026.
- Keeps your scoring model and explains whatever it decides
- Customer screens ship as a software kit for your app
- Evidence packs ready for complaints, audits and supervisors
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SIGIL
Mandates and proof for AI agents
Know which agent. Know who sent it. Know what it may do.
Your customers are about to send AI agents to their accounts. SIGIL lets them give each agent a signed mandate with a scope, limits and an end date. It checks every agent request against that mandate and records the result in a tamper-evident black box.
- Signed, revocable mandates set by the customer
- Allow, ask or deny on every request, with the reason
- Evidence for disputes, complaints and supervisors
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KEEL
Treasury and brakes for agents' money
Agents can spend. KEEL decides how much.
KEEL gives every agent an allowance worked out from the business's real cash forecast. It checks each spend before it happens and stops a runaway agent, a team or the whole company in one move. Every agent payment lands in a ledger auditors can trust.
- Limits that move with the cash forecast
- A kill switch with three levels
- A ledger of every agent payment and its reason
One ledger underneath.
All three products write to the same decision ledger. Each entry records what was decided, by whom or by what, on which data and under which rule or mandate. Entries are chained by hash and time-stamped, so nobody can quietly rewrite history.
| Time | Who decided | What | On what basis | Explanation | Human review | Within limits | Seal |
|---|---|---|---|---|---|---|---|
| 09:14:03 | Scorecard v4.2Credit model | Decline: pay in 6, €680 | R-17: commitments 52% of incomeR-09: returned direct debits | ShownVersion E-14, English | RequestedBy the customer at 09:16 | — | 7f3c…a1 |
| 09:41:12 | Trip plannerAgent acting for A. Novak | Pay €186: rail ticket | Mandate M-0193Travel, €900 per booking | RecordedWithin mandate | Not needed | Yes€606 of €2,000 this month | 9c0d…4e |
| 10:15:30 | Research agentAgent for Acme Ltd | API spend €18.40 | Budget B-12Research tools | RecordedNormal rate | Not needed | Yes€212 of €600 today | e04a…7b |
| 10:17:02 | KEEL gateAutomatic control | Pause Research agent | 31 calls a minuteNormal rate is 1.2 | RecordedAnomaly rule K-04 | Owner askedApprove or keep paused | StoppedSpending 26× normal | 55d2…c9 |
| 10:20:47 | Unsigned botNo verified identity | Balance request | No mandateNo signature | RecordedBlocked, customer told | Not needed | — | c3e9…12 |
| 11:31:18 | M. KovalenkoCredit reviewer | Approve €400 on review | Case R-2611-0417Refund confirmed in transactions | ShownVersion E-15, English | Done2 h 15 m after the request | — | 1b77…0c |
Explains any model
Works beside your scoring and decision engine. There is nothing to replace.
Answers in plain language
Teams ask questions in words. Every answer shows the SQL that produced it.
Keeps personal data minimal
Stores references and hashes where it can, rather than copies of customer data.
Runs where your data lives
Deploy in your cloud region or on your own infrastructure.
The rules arrive on a schedule.
The dates that matter to lenders and payment firms in the EU, the UK and the UAE.
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UAE
Published
Central Bank guidance on AI and machine learning
Banks are expected to explain AI-driven decisions and keep human oversight of credit decisions.
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UK
In force
Data (Use and Access) Act safeguards
New rules for significant automated decisions, including human intervention and the right to contest.
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EU
In force
Distance contracts for financial services
Online tools must come with adequate explanations, and a person on request.
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EU
In 16 days
Consumer Credit Directive (CCD2) applies
Borrowers gain rights to an explanation, human intervention, to give their view and to a review of automated credit decisions.
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EU
In about 8 months
Anti-Money Laundering Regulation applies
Automated decisions to accept or refuse customers need meaningful human intervention.
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EU
In about 13 months
AI Act duties for credit scoring
High-risk obligations apply to creditworthiness assessment: human oversight, logging and explanations.
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EU
Expected 2028
Payment Services Regulation
Expected to apply, with new rules on fraud and on how payments are authorised.
Sources
- Directive (EU) 2023/2225 on credit agreements for consumers, EUR-Lex
- Data (Use and Access) Act 2025 (Commencement No. 6) Regulations 2026, legislation.gov.uk
- Directive (EU) 2023/2673 on distance financial services contracts, Elvinger Hoss
- Regulation (EU) 2024/1624 on anti-money laundering, EUR-Lex
- AI Omnibus, Regulation (EU) 2026/1744, National Law Review
- Payment Services Regulation in 2026, Sopra Steria
- Gartner forecast on AI agents in B2B purchasing, Digital Commerce 360
What we hold ourselves to.
Show the evidence.
Every sentence we generate points to the data and the rule behind it.
Leave the decision with you.
We explain, route and record decisions. Your people and your models make them.
Make human review real.
We measure review quality, including test cases that show whether reviewers truly check.
Collect less.
Minimal personal data, clear retention and deployment in your region.
CCD2 applies on 20 November 2026.CCD2 applies now.
Time leftIn force for
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Book a readiness diagnostic. We map your automated credit decisions against the new consumer rights and show you what is missing. For SIGIL and KEEL, ask about the design-partner programme.
hello@phainly.com