Feedback on AI lawmaking submitted to European Commission's AI Office on 8 Sep 2025
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Cite as: Mauricio Del Pozzo Schneider and Harshvardhan J. Pandit, "AIAL Feedback to European Commission's AI Act High-Risk Targeted Consultation" AI Accountability Lab (AIAL). https://aial.ie/research/policy/consultation-2025-EC-AIAct-HighRisk DOI: 10.5281/zenodo.17127738
This document represents the answers prepared by the team at AI Accountability Lab (AIAL) for the Targeted Stakeholder Consultation on the Classification of AI Systems as High-Risk, conducted by the European Commission’s AI Office as part of its duties under the AI Act. The consultation was open for 6 weeks from 6th June until 18th July 2025, during which the AIAL team submitted its response.
The AIAL team sought to identify aspects of the AI Act’s high-risk criteria and associated procedures that require clarification due to uncertainties regarding its scope, undefined terms, or contradictions regarding its own provisions and their interactions with the GDPR. As the scope of the AI Act’s high-risk activities defined in Annex III is vast, we focused on questions related to Clause 3 regarding Education and Vocational Training institutions due to our familiarity with the processes and stakeholders involved.
This report provides an expanded version of the responses submitted during the consultation, with the intent to preserve their intended meaning while expanding on the details and clarifications as the original consultation imposed an extremely short character limit. Due to the focus on education domain for Annex III(3), only specific questions from Sections 2, 3, 4, and 5 of the consultation were selected (i.e. Questions 16, 33, 41, 42, 44, 51). The structure of the document follows the same format and order as the questions posed in the consultation, where each question is followed by the AIAL team’s corresponding notes and responses.