GuidanceGuidancev1.0.0

A human in the loop does not make a system low-risk

Human involvement does not change the intended purpose and therefore has no effect on classification under Article 6(2). Human oversight is a compliance requirement for high-risk systems, not an escape from the classification.

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Identifier: praxikon:eu:ai-act:guidance:guidance-high-risk-human-involvement-does-not-declassify
Payload hash (sha256): e0dab5a5fe2940b50bf147b06dee417a119fbe3888f65e39c8df060913aebfea

Citation line

Praxikon, "A human in the loop does not make a system low-risk", praxikon:eu:ai-act:guidance:guidance-high-risk-human-involvement-does-not-declassify@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 e0dab5a5fe2940b50bf147b06dee417a119fbe3888f65e39c8df060913aebfea

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.

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The obligation this hangs off

1 of 1 shown

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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, section 2.1, paragraphs (70) and (71)
  praxikon:eu:ai-act:source:commission-draft-high-risk-classification-guidelines
  Open official source
Via
No condition or exception recorded on this object.
Consequence
- ObligationAnnex III: high-risk AI
  praxikon:eu:ai-act:obligation:annex-iii-high-risk

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.

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, section 2.1, paragraphs (70) and (71)
  praxikon:eu:ai-act:source:commission-draft-high-risk-classification-guidelines
  Open official source
Via
No condition or exception recorded on this object.
Consequence
- ActorDeployer
  praxikon:eu:ai-act:actor:deployer
- ActorProvider of an AI system
  praxikon:eu:ai-act:actor:provider

What this object states

Official fact

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

The draft guidelines of 19 May 2026 on the classification of high-risk AI, which are not binding, state in paragraph (70) that the only relevant determinant for qualification under Article 6(2) is whether the intended purpose of the system includes one of the use cases listed in Annex III, that human involvement cannot change the purpose and area in which a system is intended to be used, and that human involvement therefore has no effect on classification. The same paragraph states that human oversight is instead a prerequisite for compliance with the rules for high-risk systems under Article 14. Paragraph (71) of this draft adds that the type and degree of human involvement may play a role for the Article 6(3) filter, but only to demonstrate that the tasks are narrow procedural or preparatory in nature or that the system only improves a previously completed human activity, and that a provider cannot categorise a system as low risk simply by adding a requirement of human involvement.
- Locator: Draft guidelines on high-risk AI classification (19 May 2026), Annex III chapter, section 2.1, paragraphs (70) and (71)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.

This defeats the most common defence in practice, namely that a human always looks at it anyway. That sentence changes nothing about the classification. Human involvement only becomes relevant when you can show that the system itself plays no more than a narrow procedural or preparatory role, and that is a far heavier test than an approval button.
- Locator: Draft guidelines on high-risk AI classification (19 May 2026), Annex III chapter, section 2.1, paragraphs (70) and (71)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.

Delete the sentence that a human is in the loop from your classification reasoning. Instead describe exactly what the system does in the decision process and at what moment. Use the degree of human involvement only as support within one of the four Article 6(3) grounds, and keep evidence that the review is genuinely substantive.
- Locator: Draft guidelines on high-risk AI classification (19 May 2026), Annex III chapter, section 2.1, paragraphs (70) and (71)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

Copy this reference into your advice, article or file. The identifier, the version and the hash keep the statement findable later, even once the dataset has moved on.

Reference

Praxikon, "A human in the loop does not make a system low-risk",
praxikon:eu:ai-act:guidance:guidance-high-risk-human-involvement-does-not-declassify@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 e0dab5a5fe2940b50bf147b06dee417a119fbe3888f65e39c8df060913aebfea,
https://www.praxikon.com/en/verkenner/guidance/guidance-high-risk-human-involvement-does-not-declassify
(https://www.praxikon.com/api/v1/entities?id=praxikon%3Aeu%3Aai-act%3Aguidance%3Aguidance-high-risk-human-involvement-does-not-declassify&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-human-involvement-does-not-declassify@1.0.0 (sha256 e0dab5a5)

BibTeX

@misc{praxikon-eu-ai-act-guidance-guidance-high-risk-human-involvement-does-not-declassify-1-0-0,
  author       = {{Praxikon}},
  title        = {A human in the loop does not make a system low-risk},
  year         = {2026},
  version      = {1.0.0},
  number       = {praxikon:eu:ai-act:guidance:guidance-high-risk-human-involvement-does-not-declassify},
  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 e0dab5a5fe2940b50bf147b06dee417a119fbe3888f65e39c8df060913aebfea},
  url          = {https://www.praxikon.com/en/verkenner/guidance/guidance-high-risk-human-involvement-does-not-declassify},
  urldate      = {2026-08-25},
  language     = {en}
}

CSL JSON

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