Software giants warn EU: Guidelines for high-risk AI go too far
The European Commission's draft guidelines for high-risk systems undermine the risk-based model of the AI Act, warns trade association BSA in a new consultation response.

What happened?
The trade association BSA (The Software Alliance) has submitted formal recommendations to the European Commission regarding the draft guidelines for classifying high-risk systems under the EU AI Act. BSA warns that the proposed guidelines abandon the original risk-based approach of the legislation. According to the draft, AI systems risk being classified as high-risk simply because other actors in the supply chain combine them with high-risk tools, or if general-purpose AI does not actively prevent downstream high-risk use.
Key facts
| Avsändare | BSA | The Software Alliance |
|---|---|
| Målregelverk | EU AI Act (riktlinjer för högrisk) |
| Huvudkritik | Överger den riskbaserade ansatsen |
”Significant revisions are needed to avoid gutting the Act’s risk-based approach.”
Why it matters
Classification as high-risk under the AI Act entails extensive regulatory requirements regarding compliance, risk management, documentation, and certification. If the threshold is lowered via secondary guidelines, standard AI components and general models risk being subjected to disproportionate administrative burdens that were not intended by the legislator.
Who is affected?
The criticism concerns software companies, developers of General Purpose AI (GPAI) models, and technology vendors that sell components in the AI supply chain within the EU. European end-users and integrators are also affected if vendors are forced to restrict features to avoid a high-risk label.
Impact on the EU
The classification of high-risk systems is a central component in the implementation of the EU AI Act. If the guidelines become too broad, software vendors across the union risk being burdened with heavy compliance requirements, which could hinder the development and implementation of AI technology within the EU.
What else you should know
BSA submitted the recommendations in collaboration with several other industry and user organizations. The Commission's final guidelines are expected to define how the criteria for high-risk systems should be interpreted in practice before the requirements come into full force.
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