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

Thank you everyone who contributed input to the consultation
It was submitted

The actual consultation form on the EC consultation website did not include
the option to upload a PDF, rather requested
input in a structured questionnaire, I have however managed to insert a
link to the working draft note as a background reference which in turn
contains a link to this thread

https://docs.google.com/document/d/15cc-DtpWqCvGZUpvlaA-PklLIivR-RjnuwXvgqK08tE/edit?tab=t.0#heading=h.ky80zbid0xb6

The note says it is work in progress/ the basis for ongoing discussions

This consultation is important because in the whole landscape mapping,
'high risk AI' is something to be aware of,
and by making explicit concepts and terminologies in use, we can keep track
of the evolution of knowledge in this domain

I ll be glad if CGs touched by this topic would contribute to elaborate a
standard vocabulary that can facilitate knowledge
exchange and reuse, because the topic is likely to grow in importance and
impact on the industry as a whole

Please continue to consider crystallizing a vocabulary and concept map for
this domain, at a minimum to support
understanding and eventually, when we coalesce, to be ready to put forward
a vocabulary for standardization.

Wishing  everyone an ongoing restful summer

PDM


On Tue, Jul 21, 2026 at 5:31 PM Lars Kersten Kroehl <lars@moltrust.ch>
wrote:

> 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
>
>
>