While I agree it doesn’t exclude “human in the loop” necessarily, but there is a lack of clarity as yet whether a decision made by an AI to flag something for manual review would also qualify as a “decision” in this context.

It’s also not explicit that the “legal effects” need be negative, just significant, which I think entering into a loan agreement probably is.

On the plus side, I don’t think it will take too long for case law to develop on these points.