EXECUTIVE SUMMARY
Eurelectric welcomes the opportunity to respond to the public consultation on high-risk classification under the Artificial Intelligence Act, which entered into force on 1 August 2024. The association has chosen to prioritise section 2 and 4 of the consultation.
Defining safety components
- Limit the “high-risk” definition to AI systems that directly impact safety components in electricity supply— and exclude supportive or peripheral algorithms.
- By clearly defining safety component, avoid unintended consequences of a broad interpretation of Art 3(4), which increases compliance without added safety.
Clarify roles and definitions
- Confirm if an entity using a high-risk AI system internally becomes both provider and deployer, and thus responsible for a Fundamental Rights Impact Assessment (FRIA) and other duties.
- Clarify terms like “input data” (Art. 26.4), “putting into service,” and “substantial modification.”
Reduce administrative burden
- Current documentation and logging demands may invalidate business cases and delay machine learning (ML) model development.
- In practice, compliance could force the shutdown of useful algorithms due to lack of resources.