The AI Act
in Five Steps

Ahcène Boubekki

Camilla MV Arffmann

Line KH Clemmensen

Sneha Das

Boris Düder

Rasmus SB Jensen

Olga Kokoulina

UCPH

UCPH

UCPH/DTU

DTU

UCPH

DTU

UCPH Law

AI Act Workshop

     The Workshop

\approx 30\:\text{participants}
7\:\text{May}\:2026
\text{Probe the state of affairs}
DATE
ATTENDANCE
OBJECTIVE
DATA
\text{10 workable responses}\\ \text{+Breakout sessions}

     AI Act

New Legislative Framework

1. Law

2. Standards

Already regulated domains (Annex I)

8 high-risk domains (Annex III)

High-risk vs the Rest

In-effect Requirements

A5: Prohibited practices (manipulation...)

A4: AI Literacy

GPAI obligations (testing, report...)

A50: transparency (inform, watermark...)

Applicability
Role
Classification
Obligations
Implementation

Applicability

     Applicability

Articles

Art. 3: Definitions of AI, GPAI, etc.

Art. 2 (3): Scope and Exceptions

 

(1) ‘AI system’ means a machine-based system that is designed to operate with varying levels of autonomy and that may exhibit adaptiveness after deployment, and that, for explicit or implicit objectives, infers, from the input it receives, how to generate outputs such as predictions, content, recommendations, or decisions that can influence physical or virtual environments.

 

(63) ‘general-purpose AI model’ means an AI model, including where such an AI model is trained with a large amount of data using self-supervision at scale, that displays significant generality and is capable of competently performing a wide range of distinct tasks regardless of the way the model is placed on the market and that can be integrated into a variety of downstream systems or applications, except AI models that are used for research, development or prototyping activities before they are placed on the market;

Generally assumed

 

Good Thing!

Applicability
Role
Classification
Obligations
Implementation


Role
 

     Role

Articles

Art. 3: Definitions

Absent from the materials

 

Obvious? Unfamiliar?

(3) ‘provider’ means a natural or legal person, public authority, agency or other body that develops an AI system or a general-purpose AI model or that has an AI system or a general-purpose AI model developed and places it on the market or puts the AI system into service under its own name or trademark, whether for payment or free of charge;

(4) ‘deployer’ means a natural or legal person, public authority, agency or other body using an AI system under its authority except where the AI system is used in the course of a personal non-professional activity;

(6) ‘importer’ means a natural or legal person located or established in the Union that places on the market an AI system that bears the name or trademark of a natural or legal person established in a third country;

(7) ‘distributor’ means a natural or legal person in the supply chain, other than the provider or the importer, that makes an AI system available on the Union market;

 

 

Art. 16: Obligations of providers of high-risk AI systems

Art. 23: Obligations of importers

Art. 24: Obligations of distributor

Art. 26: Obligations of deployers of high-risk AI systems

 

 

 

 

 


 

Art. 25: Responsibilities along the AI value chain

 

Most were providers (developers)

Applicability
Role
Classification
Obligations
Implementation



Classification

     Classification

Articles

Art. 3: Definitions

(2) ‘risk’ means the combination of the probability of an occurrence of harm and the severity of that harm;

 

 

Art. 6(1): Safety component or whole of a product under Annex I

Annex I

List of Union harmonisation legislation

 

machinery, toys, craft and watercraft, lifts, explosive protective equipments, radio equipments, pressure equipments, cablesways, personal protective equipments, fuels, medical devices, in vitro diagnostics

Annex III

High-risk AI systems referred to in Article 6(2)

 

Biometrics, Critical infrastructure, employment, essential services, law enforcement, migration, justice

 

 

 

Art. 6(2): AI systems referred to in Annex III

 

 

 

 

Art. 6(3): Narrow procedural task

Under 6 (1) high-risk is not automatic!

 

risks to health, safety, and fundamental rights?

     GPAI

Query

Main Agent

agent

Memory

Planner

Censor

Output

Web

Tools

Scripts

etc.

agent

agent

Main Agent

Preparatory Work

Improve results

Narrow procedural task

Control

the AI system is intended to detect decision-making patterns or deviations from prior decision-making patterns and is not meant to replace or influence the previously completed human assessment, without proper human review; or

     Classification

Articles

Art. 3: Definitions

 

 

Art. 6(1): Safety component or whole of a product under Annex I

 

 

 

Art. 6(2): AI systems referred to in Annex III

 

 

 

 

Art. 6(3): Narrow procedural task

(4) 'profiling' means any form of automated processing of personal data consisting of the use of personal data to evaluate certain personal aspects relating to a natural person, in particular to analyse or predict aspects concerning that natural person's performance at work, economic situation, health, personal preferences, interests, reliability, behaviour, location or movements;

(4) 'profiling' means any form of automated processing of personal data consisting of the use of personal data to evaluate certain personal aspects relating to a natural person, in particular to analyse or predict aspects concerning that natural person's performance at work, economic situation, health, personal preferences, interests, reliability, behaviour, location or movements;

No exception if PROFILING!

 

Human Involvement does not matter!

 

All based on

intended purpose

(12) ‘intended purpose’ means the use for which an AI system is intended by the provider, including the specific context and conditions of use, as specified in the information supplied by the provider in the instructions for use, promotional or sales materials and statements, as well as in the technical documentation;

More intuition than rules...

 

Tried to escape with
human in the loop

Applicability
Role
Classification
Obligations
Implementation




Obligations
 

     Obligations

Articles

Art. 4: Literacy

 

Art. 50: Transparency

 

 

Art. 9-15,17,43,72,73: for high risk

High-Risk Paths:

Annex I: Follow sector procedure and report to sector authtorities

 

Annex III: self assessment, register in EU database,
                 if filter, justify!
                 in some cases: risk to fund. rights assessment.

High-risk = Conformity assessment

FOR ALL AI SYSTEMS!

Uncertainty among participants

 

Overlooked AI literacy!

 

...bias due to format...

 

Frictions
Legal vs Engineers

Applicability
Role
Classification
Obligations
Implementation





Implementation

     Implementation

Articles

Art. 40: Harmonized Standards

Which metric?

 

Which tools?

 

Threshold or
just reporting?

Standards = Presumption of Conformity

The AI Act
in Five Steps