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

Dear all,

I have read the submitted document on behalf of the AIKR CG with input from
the AI Agent Protocol and reference to the A2WF CG.

I also checked for the complete list of all relevant documents of the EU AI
Act pertaining to its phased introduction and roll-out.
https://share.google/aimode/oHyXdvECN20Fw1mZb

As stated in earlier posts I am particularly interested in the development
of digital twins for terrestrial and marine (coastal and ocean)
(very)(large) ecosystems that can include one or more of the three
components of sustainable development,  i.e. economic development, social
development or ecological management.

The EU has developed the BioDT, DestinE and EDITO (ocean digital twin)
frameworks.
Of these the EDITO is relevant for projects that we are developing in
collaboration with the UNEP Caribbean Environmental Programme (CEP-UNEP),
Grid Arendal Blue Carbon Program, the UNESCO Man and Biosphere Programme,
which recently designated the Dutch Caribbean island of Aruba as the second
full territory Biosphere Reserve on earth.
Because Aruba is one of the 13 Overseas Countries and Territories of the
European Union we will be using the EU AI Act and other relevant documents
to guide the entire process of designing an ocean digital twin for Small
Island Developing States (SIDS),  and use the Caribbean and South Pacific
as geographical frameworks of reference.

I have dealt with complex legislation at the UN level for climate, ocean
and marine biodiversity, and also waste management and pollution issues,
but the EU AI Act is the single most complex legislation I have encountered
so far.
Because I now must combine both multiple legal UN frameworks (treaties) and
the EU AI Act to design the ocean digital twin for SIDS I must create a
strategy,  complete with planning, deliverables ( both UN treaty and EU AI
Act defined and mandatory) for the creation of proof of concept and pilot
project phases.

For the preparatory,  preliminary processes I am considering doing this in
a manner that allows StratML application.

But I am also open to suggestions for frameworks to assess which parts of
the EU AI Act are applicable for the development of a digital twin for the
ocean.

The current use of technologies applied in ocean observation and monitoring
covers a scope of artificial intelligence applications that exceeds the
boundaries of what is framed in the EU AI Act.

The creation of a proof of concept project and pilot project could provide
valuable case study testing of the EU AI Act.

I will soon be making more information available on the ecodigitaltwins.org
website (under construction) on the setup.

Again I am open to suggestions on how to proceed with the strategy,
planning and automated processes for designing such a digital twin and als
welcome the possibility of collaboration.

Milton Ponson
Rainbow Warriors Core Foundation
CIAMSD Institute-ICT4D Program
+2977459312
PO Box 1154, Oranjestad
Aruba, Dutch Caribbean

On Sat, Jul 25, 2026, 04:49 Paola Di Maio <paoladimaio10@gmail.com> wrote:

> 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
>>
>>
>>