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High-Risk AI Systems Under the EU AI Act: Are You Affected?

Dilip Kumar MulluriMarch 10, 20266 min read

The high-risk category carries the heaviest obligations under the EU AI Act. Find out whether your systems qualify — and what to do if they do.

Most of the EU AI Act's substantive obligations target one category: high-risk AI systems. If your systems fall into this bucket, compliance is mandatory and non-trivial. If they don't, your obligations are far lighter. So the first question every organization should answer is simple: am I operating a high-risk system?

Two routes into 'high risk'

An AI system is generally considered high-risk in two situations. First, when it is a safety component of a product already covered by EU product-safety legislation — medical devices being a prime example. Second, when it is used in specific sensitive areas listed in the Act.

Sensitive areas that commonly qualify

  • Biometric identification and categorization of people.
  • Critical infrastructure management.
  • Education and vocational training (e.g. scoring exams or admissions).
  • Employment, recruitment, and worker management.
  • Access to essential services, including credit scoring.
  • Law enforcement, migration, and administration of justice.

If you are affected

High-risk systems require a risk-management system, data governance, technical documentation, record-keeping, transparency to users, human oversight, and robustness and cybersecurity measures. Providers must also undergo a conformity assessment and register the system before placing it on the market.

Misclassifying a high-risk system as low-risk is one of the costliest mistakes an organization can make — both legally and reputationally.

Because the stakes of misclassification are high, this is precisely where expert review pays off. A structured readiness assessment removes the guesswork and gives you a defensible position on where each of your systems stands.

Written by Dilip Kumar Mulluri at Ethos AI Consultancy. Need help with AI compliance? Get in touch →

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