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ARTICLE · 10 JULY 2025

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AI Legal Watch: July 2

Baker Botts L.L.P.
Baker Botts L.L.P.
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Baker Botts L.L.P.

Baker Botts L.L.P.

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The European Commission recently launched a public consultation on the implementation of the AI Act, primarily focused on the classification...

United KingdomTechnology
Sarah J. Dodson
Sarah J. Dodson
Richard B. Harper
Richard B. Harper
Margaret M. Welsh
Margaret M. Welsh

EU Launches Consultation on High-Risk AI Systems

Ben Bafumi*

The European Commission recently launched a public consultation on the implementation of the AI Act, primarily focused on the classification (and ultimate regulation) of "high risk" AI systems. The AI Act employs a risk-based classification structure—unacceptable risk (which is prohibited), high risk, limited risk, and minimal risk—to properly guide the development, marketing, and use of AI systems. The AI Act defines the following categories as high risk: (1) embedded systems, which are considered high risk because of their integration into regulated, and (2) standalone systems, which are considered high-risk because of their intended purpose. If a device is high risk it must adhere to various legal obligations, including risk and quality management, third-party conformity assessments, technical documentation, transparency measures, and human oversight requirements.

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