EU seeks input on high-risk AI rules

The European Commission’s AI Office has opened a survey on high-risk AI systems. Feedback will inform guidelines on the practical implementation of the high-risk regime under the EU AI Act. The survey closes on 18 July 2025.

The Commission’s survey is targeted at both providers and deployers of high-risk AI. Questions that will be of interest to financial services firms include:

• Whether any AI systems should be added to the list of high-risk use cases in Annex III EU AI Act
• Whether any AI use cases should be removed from that list
• Whether the concept of “substantial modification” of an AI system needs clarifying
• Whether the rules for deployers or providers of high-risk AI systems need clarifying
• Whether the interplay with other EU legislation needs clarifying
• Whether there are any challenges to complying with the value chain obligations

The Commission will provide guidelines on the rules for high-risk classification of AI systems by 2 February 2026 along with a list of practical examples of use cases of AI systems that are high-risk.