The EU AI Act Classification Playbook
Classification methodology, exemption boundaries, and the documentation your organization needs to meet obligations already in effect.
Download Now: The EU AI Act Classification Playbook
Your AI inventory probably doesn’t match how a regulator would classify it.
The Commission’s draft guidelines answer a question the market has been guessing at since the Act entered into force in August 2024: how intended purpose actually gets determined. It’s not your technical architecture. It’s what your organization has collectively represented across every channel it controls, technical docs, marketing, sales decks, contracts, and case studies, read together as one legal instrument.
Most organizations built their inventory around technical function or use case category alone. Under this methodology, that inventory is incomplete, and the gap between what you documented and what you can defend is where scrutiny will land first.
This playbook is adapted from a working session led by Airia’s Chief Trust Officer and General Counsel, giving you the legal and operational view at once.
Key Takeaways:
- Intended purpose is a legal term of art, not a marketing concept. Your technical docs, product pages, sales decks, and case studies all count as evidence, and inconsistencies between them work against you.
- A single terms of service carve out won’t hold. The guidelines require your commercial positioning to consistently limit high-risk use across every material you publish, not just your contracts.
- The Article 6(3) filter is narrower than most teams assume. It’s unavailable for any system that profiles natural persons, and all four conditions must be interpreted narrowly, not generously.
- Deployers become providers faster than expected. Affixing your name to a system, modifying its intended purpose, or making a substantial modification can shift you into full provider obligations under Article 25.
- None of this can be built retroactively. Pre-market filter self-assessments, failure mode analysis, and classification rationale all need to exist before the December 2027 deadline, not after.
Download the guide to learn more.