Re: UPDATED, for immediate action! [was] Draft EU Commission guidelines on the classification of high-risk AI system

Greetings AI KR CG Participants,

I build DID/VC verification infrastructure for autonomous agents, including a deployed layer that anchors per-action verdicts against a committed mandate. I comment here because Section 2 touches a problem I run in production: the relationship between an evidentiary record and the authorization it is supposed to attest.

== On §2.2 and §2.3: the record and the delegation should anchor at the same point ==

Sections 2.2 (evidentiary record) and 2.3 (speaks-for authority) address two halves of one question, and the draft does not yet connect them.

A content-addressed record of a commitment and decision establishes that an action occurred and by which identity. It does not, on its own, establish that the delegation authorizing that action held at the moment the action was taken. For a static system this gap is invisible. For an agentic system whose authorization can be narrowed, delegated onward, or revoked between classification and action, it is the substance of the question 2.3 raises: after a fork, identifying which instance acted is not the same as establishing that the acting instance was authorized at that time.

The practical consequence for record-keeping guidance: an evidentiary record satisfying Article 12 should commit the identity, the decision, and the authorization state in force at the moment of the action. Without the last, a fork preserves the classification but not the binding that made the action accountable. Whether this belongs in the guidelines or in the referenced technical work (W3C AI Agent Protocol CG) is a scoping question for the group.

Whether this bears on the Article 25(1) provider-obligation transfer — where a fork or substantial modification may move provider status to another party — is a legal question outside our competence.

Best,
Lars 






> Am 21.07.2026 um 16:07 schrieb Paola Di Maio <paola.dimaio@gmail.com>:
> 
> Greetings AI KR CG Participants