Could Your AI Systems Already Be High-Risk Under the EU AI Act?

The European Commission’s latest draft guidelines provide much-needed clarity on how organizations should classify high-risk AI systems under Article 6 of the EU AI Act. However, they also raise an important question for enterprises: could your existing AI systems already be considered high-risk without you realizing it?
The answer may depend on more than what the technology does.
Under the EU AI Act, an AI system’s intended purpose plays a central role in determining its risk classification. This means how a system is documented, marketed, deployed, and used can be just as important as its technical capabilities.
Article 6 outlines two routes through which an AI system may be classified as high-risk. These include AI used within certain regulated products and AI deployed in sensitive use cases that could significantly affect people’s health, safety, or fundamental rights.
For enterprise teams, this creates several immediate questions:
Which AI systems across the organization fall within the scope of Article 6?
Does current documentation accurately reflect how each system is being used?
Could the Article 6(3) exemption apply, and what evidence would be required?
What should legal, governance, and technology teams be doing now?
Airia’s on-demand webinar, EU AI Act: What It Actually Requires and Enterprises Need to Do Now, breaks down the new guidance and turns it into a practical decision framework.
The session covers the two pathways to high-risk classification, the limitations of the Article 6(3) self-assessment mechanism, and the steps enterprises can take to assess their AI systems more confidently.
Access the on-demand webinar to understand what the latest guidance means for your AI governance program and what your organization should do next.