Feedback on AI lawmaking submitted to European Commission's AI Office on 7 Nov 2025
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Cite as: Harshvardhan J. Pandit, "AIAL's comments for Targeted stakeholder consultation on the Commissions Draft Guidance on Article 73 AI Act - Incident Reporting (High-Risk AI Systems)" AI Accountability Lab (AIAL). https://aial.ie/research/policy/consultation-2025-EC-AIAct-IncidentReporting DOI: 10.5281/zenodo.17559043
This document represents the answers prepared by the team at AI Accountability Lab (AIAL) for the Targeted stakeholder consultation on the Commission’s Draft Guidance on Article 73 AI Act - Incident Reporting (High-Risk AI Systems), conducted by the European Commission’s AI Office as part of its duties under the AI Act. The consultation was open from 26th September until 7th November 2025, during which the AIAL team submitted its response.
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. 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. The content from the guidelines and the consultation forms is provided in a box along with the relevant paragraph number, with the AIAL’s comments provided below it.