Co-authored comments submitted to the European Commission's targeted consultation on draft guidelines for classifying high-risk AI systems under Article 6 of the EU AI Act, as part of a cross-disciplinary working group spanning legal, technical, policy, trust & safety, and communications expertise, organized by Vivi Cecilie Galschiødt Svendsen.

The consultation asked two questions of each section under review: is this guidance clear, and is an example missing or wrong.

Specific contributions: analysis of Section III.2.1, addressing a scope gap in the list of product laws referenced for classification purposes; analysis of Section III.2.2.2, addressing the guidelines' definition of a safety component; and analysis of Section III.2.3, addressing the application of third-party conformity assessment rules.

Co-authors: Vivi Cecilie Galschiødt Svendsen, Courage Kimber, Jacqueline Muturi, Rucha Patki, Jesuloluwa Soile, Ioulia Kalpakoula, and others, organized by Vivi Cecilie Galschiødt Svendsen

Links: European Commission consultation page

Skills demonstrated: EU regulatory analysis, AI governance, cross-disciplinary policy drafting, classification and conformity assessment frameworks, coalition-based advocacy

Relevant context: Article 6 governs which AI systems are legally classified as high-risk under the EU AI Act, determining whether the Act's most stringent obligations apply. The Commission's draft guidelines interpret that classification for providers and deployers across the EU.