high-risk ai system
Subject Roles in the EU AI Act: Mapping and Regulatory Implications
The European Union's Artificial Intelligence Act (Regulation (EU) 2024/1689) establishes the world's first comprehensive regulatory framework for AI systems through a sophisticated ecosystem of interconnected subjects defined in Article 3. This paper provides a structured examination of the six main categories of actors - providers, deployers, authorized representatives, importers, distributors, and product manufacturers - collectively referred to as "operators" within the regulation. Through examination of these Article 3 definitions and their elaboration across the regulation's 113 articles, 180 recitals, and 13 annexes, we map the complete governance structure and analyze how the AI Act regulates these subjects. Our analysis reveals critical transformation mechanisms whereby subjects can assume different roles under specific conditions, particularly through Article 25 provisions ensuring accountability follows control. We identify how obligations cascade through the supply chain via mandatory information flows and cooperation requirements, creating a distributed yet coordinated governance system. The findings demonstrate how the regulation balances innovation with the protection of fundamental rights through risk-based obligations that scale with the capabilities and deployment contexts of AI systems, providing essential guidance for stakeholders implementing the AI Act's requirements.
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An Analysis of the New EU AI Act and A Proposed Standardization Framework for Machine Learning Fairness
Teodorescu, Mike, Sun, Yongxu, Bhatia, Haren N., Makridis, Christos
The European Union's AI Act represents a crucial step towards regulating ethical and responsible AI systems. However, we find an absence of quantifiable fairness metrics and the ambiguity in terminology, particularly the interchangeable use of the keywords transparency, explainability, and interpretability in the new EU AI Act and no reference of transparency of ethical compliance. We argue that this ambiguity creates substantial liability risk that would deter investment. Fairness transparency is strategically important. We recommend a more tailored regulatory framework to enhance the new EU AI regulation. Further-more, we propose a public system framework to assess the fairness and transparency of AI systems. Drawing from past work, we advocate for the standardization of industry best practices as a necessary addition to broad regulations to achieve the level of details required in industry, while preventing stifling innovation and investment in the AI sector. The proposals are exemplified with the case of ASR and speech synthesizers.
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TAI Scan Tool: A RAG-Based Tool With Minimalistic Input for Trustworthy AI Self-Assessment
Davvetas, Athanasios, Ziouvelou, Xenia, Dami, Ypatia, Kaponis, Alexios, Giouvanopoulou, Konstantina, Papademas, Michael
This paper introduces the TAI Scan Tool, a RAG-based TAI self-assessment tool with minimalistic input. The current version of the tool supports the legal TAI assessment, with a particular emphasis on facilitating compliance with the AI Act. It involves a two-step approach with a pre-screening and an assessment phase. The assessment output of the system includes insight regarding the risk-level of the AI system according to the AI Act, while at the same time retrieving relevant articles to aid with compliance and notify on their obligations. Our qualitative evaluation using use-case scenarios yields promising results, correctly predicting risk levels while retrieving relevant articles across three distinct semantic groups. Furthermore, interpretation of results shows that the tool's reasoning relies on comparison with the setting of high-risk systems, a behaviour attributed to their deployment requiring careful consideration, and therefore frequently presented within the AI Act.
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Foundations for Risk Assessment of AI in Protecting Fundamental Rights
Rotolo, Antonino, Ferrigno, Beatrice, Godinez, Jose Miguel Angel Garcia, Novelli, Claudio, Sartor, Giovanni
This chapter introduces a conceptual framework for qualitative risk assessment of AI, particularly in the context of the EU AI Act. The framework addresses the complexities of legal compliance and fundamental rights protection by itegrating definitional balancing and defeasible reasoning. Definitional balancing employs proportionality analysis to resolve conflicts between competing rights, while defeasible reasoning accommodates the dynamic nature of legal decision-making. Our approach stresses the need for an analysis of AI deployment scenarios and for identifying potential legal violations and multi-layered impacts on fundamental rights. On the basis of this analysis, we provide philosophical foundations for a logical account of AI risk analysis. In particular, we consider the basic building blocks for conceptually grasping the interaction between AI deployment scenarios and fundamental rights, incorporating in defeasible reasoning definitional balancing and arguments about the contextual promotion or demotion of rights. This layered approach allows for more operative models of assessment of both high-risk AI systems and General Purpose AI (GPAI) systems, emphasizing the broader applicability of the latter. Future work aims to develop a formal model and effective algorithms to enhance AI risk assessment, bridging theoretical insights with practical applications to support responsible AI governance.
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Beware! The AI Act Can Also Apply to Your AI Research Practices
Wernick, Alina, Meding, Kristof
The EU has become one of the vanguards in regulating the digital age. A particularly important regulation in the Artificial Intelligence (AI) domain is the EU AI Act, which entered into force in 2024. The AI Act specifies -- due to a risk-based approach -- various obligations for providers of AI systems. These obligations, for example, include a cascade of documentation and compliance measures, which represent a potential obstacle to science. But do these obligations also apply to AI researchers? This position paper argues that, indeed, the AI Act's obligations could apply in many more cases than the AI community is aware of. In our analysis of the AI Act and its applicability, we contribute the following: 1.) We give a high-level introduction to the AI Act aimed at non-legal AI research scientists. 2.) We explain with everyday research examples why the AI Act applies to research. 3.) We analyse the exceptions of the AI Act's applicability and state that especially scientific research exceptions fail to account for current AI research practices. 4.) We propose changes to the AI Act to provide more legal certainty for AI researchers and give two recommendations for AI researchers to reduce the risk of not complying with the AI Act. We see our paper as a starting point for a discussion between policymakers, legal scholars, and AI researchers to avoid unintended side effects of the AI Act on research.
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The Unified Control Framework: Establishing a Common Foundation for Enterprise AI Governance, Risk Management and Regulatory Compliance
Eisenberg, Ian W., Gamboa, Lucía, Sherman, Eli
The rapid adoption of AI systems presents enterprises with a dual challenge: accelerating innovation while ensuring responsible governance. Current AI governance approaches suffer from fragmentation, with risk management frameworks that focus on isolated domains, regulations that vary across jurisdictions despite conceptual alignment, and high-level standards lacking concrete implementation guidance. This fragmentation increases governance costs and creates a false dichotomy between innovation and responsibility. We propose the Unified Control Framework (UCF): a comprehensive governance approach that integrates risk management and regulatory compliance through a unified set of controls. The UCF consists of three key components: (1) a comprehensive risk taxonomy synthesizing organizational and societal risks, (2) structured policy requirements derived from regulations, and (3) a parsimonious set of 42 controls that simultaneously address multiple risk scenarios and compliance requirements. We validate the UCF by mapping it to the Colorado AI Act, demonstrating how our approach enables efficient, adaptable governance that scales across regulations while providing concrete implementation guidance. The UCF reduces duplication of effort, ensures comprehensive coverage, and provides a foundation for automation, enabling organizations to achieve responsible AI governance without sacrificing innovation speed.
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Logical Modalities within the European AI Act: An Analysis
Lawniczak, Lara, Benzmüller, Christoph
The paper presents a comprehensive analysis of the European AI Act in terms of its logical modalities, with the aim of preparing its formal representation, for example, within the logic-pluralistic Knowledge Engineering Framework and Methodology (LogiKEy). LogiKEy develops computational tools for normative reasoning based on formal methods, employing Higher-Order Logic (HOL) as a unifying meta-logic to integrate diverse logics through shallow semantic embeddings. This integration is facilitated by Isabelle/HOL, a proof assistant tool equipped with several automated theorem provers. The modalities within the AI Act and the logics suitable for their representation are discussed. For a selection of these logics, embeddings in HOL are created, which are then used to encode sample paragraphs. Initial experiments evaluate the suitability of these embeddings for automated reasoning, and highlight key challenges on the way to more robust reasoning capabilities.
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A Blockchain-Enabled Approach to Cross-Border Compliance and Trust
As artificial intelligence (AI) systems become increasingly integral to critical infrastructure and global operations, the need for a unified, trustworthy governance framework is more urgent that ever. This paper proposes a novel approach to AI governance, utilizing blockchain and distributed ledger technologies (DLT) to establish a decentralized, globally recognized framework that ensures security, privacy, and trustworthiness of AI systems across borders. The paper presents specific implementation scenarios within the financial sector, outlines a phased deployment timeline over the next decade, and addresses potential challenges with solutions grounded in current research. By synthesizing advancements in blockchain, AI ethics, and cybersecurity, this paper offers a comprehensive roadmap for a decentralized AI governance framework capable of adapting to the complex and evolving landscape of global AI regulation.
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AICat: An AI Cataloguing Approach to Support the EU AI Act
Golpayegani, Delaram, Pandit, Harshvardhan J., Lewis, Dave
The European Union's Artificial Intelligence Act (AI Act) requires providers and deployers of high-risk AI applications to register their systems into the EU database, wherein the information should be represented and maintained in an easily-navigable and machine-readable manner. Given the uptake of open data and Semantic Web-based approaches for other EU repositories, in particular the use of the Data Catalogue vocabulary Application Profile (DCAT-AP), a similar solution for managing the EU database of high-risk AI systems is needed. This paper introduces AICat - an extension of DCAT for representing catalogues of AI systems that provides consistency, machine-readability, searchability, and interoperability in managing open metadata regarding AI systems. This open approach to cataloguing ensures transparency, traceability, and accountability in AI application markets beyond the immediate needs of high-risk AI compliance in the EU. AICat is available online at https://w3id.org/aicat under the CC-BY-4.0 license.
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COMPL-AI Framework: A Technical Interpretation and LLM Benchmarking Suite for the EU Artificial Intelligence Act
Guldimann, Philipp, Spiridonov, Alexander, Staab, Robin, Jovanović, Nikola, Vero, Mark, Vechev, Velko, Gueorguieva, Anna, Balunović, Mislav, Konstantinov, Nikola, Bielik, Pavol, Tsankov, Petar, Vechev, Martin
The EU's Artificial Intelligence Act (AI Act) is a significant step towards responsible AI development, but lacks clear technical interpretation, making it difficult to assess models' compliance. This work presents COMPL-AI, a comprehensive framework consisting of (i) the first technical interpretation of the EU AI Act, translating its broad regulatory requirements into measurable technical requirements, with the focus on large language models (LLMs), and (ii) an open-source Act-centered benchmarking suite, based on thorough surveying and implementation of state-of-the-art LLM benchmarks. By evaluating 12 prominent LLMs in the context of COMPL-AI, we reveal shortcomings in existing models and benchmarks, particularly in areas like robustness, safety, diversity, and fairness. This work highlights the need for a shift in focus towards these aspects, encouraging balanced development of LLMs and more comprehensive regulation-aligned benchmarks. Simultaneously, COMPL-AI for the first time demonstrates the possibilities and difficulties of bringing the Act's obligations to a more concrete, technical level. As such, our work can serve as a useful first step towards having actionable recommendations for model providers, and contributes to ongoing efforts of the EU to enable application of the Act, such as the drafting of the GPAI Code of Practice.
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