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GuidanceGuidancev1.0.0

The Article 6(3) filter: four exhaustive grounds, to be read narrowly

A system falling within Annex III can still stay outside high-risk if one of four grounds is met and the system does not perform profiling. The provider makes that call itself, must document the assessment before placing the system on the market, and must register the system in the EU database.

The official source remains authoritative. This is general information about obligations and not legal advice. See this object on the map

Address and citation

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Identifier
praxikon:eu:ai-act:guidance:guidance-high-risk-article-6-3-filter-mechanism
Payload hash (sha256)
d6fc330373b2b9b704080d8d34c00f20be28c6ee7ba1357e09733209bdfd75ef

Citation line

Praxikon, "The Article 6(3) filter: four exhaustive grounds, to be read narrowly", praxikon:eu:ai-act:guidance:guidance-high-risk-article-6-3-filter-mechanism@1.0.0, dataset praxikon:sys:registry:dataset:ai-act-implementation-graph 2.1.0 (schema 1.4.0), effective_at 2026-08-08T00:00:00.000Z, known_at 2026-08-14T00:00:00.000Z, sha256 d6fc330373b2b9b704080d8d34c00f20be28c6ee7ba1357e09733209bdfd75ef
Version
1.0.0
Legal time (effective_at)
8 August 2026
Knowledge time (known_at)
8 August 2026
Closed on
Not closed
Topics
guidance

Review status: Placed against the official source (8 August 2026). Next check due by 4 February 2027. The check date is the knowledge date of this version; no later recheck has been recorded.

What this object links to

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The obligation this hangs off

1 of 1 shown

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  1. Source

    Official fact on this object, with its locator.

    • Draft guidelines on the classification of high-risk AI systems

      Locator: Draft guidelines on high-risk AI classification (19 May 2026), Annex III chapter, sections 2.7, 2.7.1, 2.7.3 and 2.7.4, paragraphs (84) to (90) and (113) to (117)

      praxikon:eu:ai-act:source:commission-draft-high-risk-classification-guidelines

      Open official source

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    Consequence

What this object is about

2 of 2 shown

The object is about this role. Undifferentiated: it does not follow that the duty rests on this role.

  1. Source

    Official fact on this object, with its locator.

    • Draft guidelines on the classification of high-risk AI systems

      Locator: Draft guidelines on high-risk AI classification (19 May 2026), Annex III chapter, sections 2.7, 2.7.1, 2.7.3 and 2.7.4, paragraphs (84) to (90) and (113) to (117)

      praxikon:eu:ai-act:source:commission-draft-high-risk-classification-guidelines

      Open official source

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    Consequence

What this object states

Official fact

Attributable to a named primary source, with a locator. Where they differ, the official source prevails.

  • According to the non-binding draft guidelines of 19 May 2026 on the classification of high-risk AI, Article 6(3) sets out four grounds on which a provider may exempt a system from high-risk classification: performing a narrow procedural task, improving the result of a previously completed human activity, detecting decision-making patterns or deviations from prior patterns without replacing or influencing the previously completed human assessment absent proper human review, and performing a preparatory task. Paragraph (88) of this draft states these grounds are exhaustive but alternative, that there is no separate independent risk test, and that they must be interpreted narrowly because Article 6(3) is an exception to rules that among other things protect fundamental rights. Paragraph (87) states the filter applies only to systems under Article 6(2) and not to systems under Article 6(1). Paragraph (89) states a system always remains high-risk where it performs profiling. Paragraph (90) adds that the filter does not apply where the system forms part of a complex system whose combined intended purpose or joint outputs materially influence an individual decision, including agentic AI. Paragraphs (113) to (116) of this draft describe that this is a self-assessment by the provider, that Article 6(4) requires documenting the assessment before placing on the market and registering in the Article 71 EU database, and that the assessment must contain at least the intended purpose, why the system falls under Article 6(2), which Article 6(3) condition applies and why, and why the system does not perform profiling. Paragraph (117) of these draft guidelines points to Articles 80 and 99 where an authority finds a system was misclassified as non high-risk to circumvent the rules.

    • Locator: Draft guidelines on high-risk AI classification (19 May 2026), Annex III chapter, sections 2.7, 2.7.1, 2.7.3 and 2.7.4, paragraphs (84) to (90) and (113) to (117)praxikon:eu:ai-act:source:commission-draft-high-risk-classification-guidelinesOpen official source

Our interpretation

Our own reading. It can change without the law changing, and it is not the position of a supervisory authority.

  • The filter is not a soft way out but a documented and visible decision. You leave the Chapter III high-risk obligations, but in exchange you appear in the public EU database and your reasoning must be available to the regulator at any time. For buyers that is a gift: the draft guidelines expressly encourage deployers to check that database to see whether a vendor relies on the exception.

    • Locator: Draft guidelines on high-risk AI classification (19 May 2026), Annex III chapter, sections 2.7, 2.7.1, 2.7.3 and 2.7.4, paragraphs (84) to (90) and (113) to (117)praxikon:eu:ai-act:source:commission-draft-high-risk-classification-guidelinesOpen official source

Recommended step

A practical step we consider appropriate. Not an obligation following from the Regulation.

  • Write the filter file in four fixed blocks: intended purpose, why it falls under Annex III, which ground you invoke with reasoning, and why there is no profiling. Never rely on the filter because the risk feels low, since that free-standing test does not exist. When procuring, always check the EU database before believing a vendor who says its system is not high-risk.

    • Locator: Draft guidelines on high-risk AI classification (19 May 2026), Annex III chapter, sections 2.7, 2.7.1, 2.7.3 and 2.7.4, paragraphs (84) to (90) and (113) to (117)praxikon:eu:ai-act:source:commission-draft-high-risk-classification-guidelinesOpen official source

When this applies

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When this does not apply

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Referring to this object

Citation block

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Reference

Praxikon, "The Article 6(3) filter: four exhaustive grounds, to be read narrowly",
praxikon:eu:ai-act:guidance:guidance-high-risk-article-6-3-filter-mechanism@1.0.0,
dataset praxikon:sys:registry:dataset:ai-act-implementation-graph 2.1.0 (schema 1.4.0),
effective_at 2026-08-08T00:00:00.000Z, known_at 2026-08-08T00:00:00.000Z,
sha256 d6fc330373b2b9b704080d8d34c00f20be28c6ee7ba1357e09733209bdfd75ef,
https://www.praxikon.com/en/verkenner/guidance/guidance-high-risk-article-6-3-filter-mechanism
(https://www.praxikon.com/api/v1/entities?id=praxikon%3Aeu%3Aai-act%3Aguidance%3Aguidance-high-risk-article-6-3-filter-mechanism&effective_at=2026-08-08&known_at=2026-08-08&lang=en, accessed 2026-08-25)

Short form

praxikon:eu:ai-act:guidance:guidance-high-risk-article-6-3-filter-mechanism@1.0.0 (sha256 d6fc3303)

BibTeX

@misc{praxikon-eu-ai-act-guidance-guidance-high-risk-article-6-3-filter-mechanism-1-0-0,
  author       = {{Praxikon}},
  title        = {The Article 6(3) filter: four exhaustive grounds, to be read narrowly},
  year         = {2026},
  version      = {1.0.0},
  number       = {praxikon:eu:ai-act:guidance:guidance-high-risk-article-6-3-filter-mechanism},
  howpublished = {AI Act Change \& Evidence Graph, dataset 2.1.0, schema 1.4.0},
  note         = {effective_at 2026-08-08T00:00:00.000Z; known_at 2026-08-08T00:00:00.000Z; sha256 d6fc330373b2b9b704080d8d34c00f20be28c6ee7ba1357e09733209bdfd75ef},
  url          = {https://www.praxikon.com/en/verkenner/guidance/guidance-high-risk-article-6-3-filter-mechanism},
  urldate      = {2026-08-25},
  language     = {en}
}

CSL JSON

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