Help Shape the Rules: High-Risk AI Consultation

The European Commission has published draft guidelines (HERE) on the classification of high-risk AI systems under Article 6 of the AI Act. The document covers both AI systems that are products or safety components of products regulated under sectoral legislation in Annex I and the use cases listed in Annex III, including biometrics, education, employment, critical infrastructure, law enforcement, migration and justice. The draft also provides examples of systems that should qualify as high-risk, as well as examples of systems that should not be classified in that way. Although the guidelines are not legally binding, they are likely to become an important reference point for providers and supervisory authorities applying Article 6 of the AI Act in practice. The Commission has also opened a public consultation on the draft, with submissions accepted until 23 July 2026.

As the issue of which systems will be classified as high risk has enormous practical relevance for all providers and users, we strongly encourage you to take part in the ongoing consultation. As a member operating a high-risk system, your input is not just an administrative task, it is a strategic opportunity to shape the rules that will govern your business. Here is why having your say is critical:

• Influence, don’t just observe: This is a crucial window to shape the implementation of Article 6 before the guidelines are finalized. By highlighting which classifications are workable and which create undue burdens, you help secure a more stable and predictable regulatory environment.
• Prevent redundant compliance: Without proactive industry input, there is a risk that the guidelines could create overlapping requirements or misinterpretations, such as conflicting with the GDPR or existing sectoral product safety laws. Your contribution helps ensure the AI Act functions with your existing compliance frameworks, not against them.
• Define the ‘Grey Zones’: Critical concepts like ‘safety component,’ ‘intended purpose,’ and the distinction between high-risk and prohibited practices are subject to interpretation. Your input helps set clear, industry-grounded boundaries, effectively protecting your organization from future legal uncertainty.

In short, your participation allows you to move from being a recipient of these regulations to a partner in defining them.

We’re calling on our community to contribute to the ongoing European Commission consultation on high-risk AI classification. Your practical, on-the-ground experience is essential for ensuring these guidelines reflect real-world operations. By sharing your feedback before July 19, 2026 deadline, you play a direct role in shaping the rules before they are finalized.

Link to the consultation: https://digital-strategy.ec.europa.eu/en/library/draft-commission-guidelines-classification-high-risk-ai-systems