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Paper · arXiv

High-Risk AI Systems and the Problem of Identity in the European AI Act

The EU Artificial Intelligence Act (AIA) establishes a lifecycle governance regime for high-risk AI systems built around ex-ante conformity assessment, post-market monitoring, and re-assessment upon "substantial modification." These obligations presuppose AI identity judgments: regulators and providers must decide when an updated system remains the same system over time. In this work, we show how this logic is clarified by the function+ framework of artifact identity, which individuates AI systems by their intended function together with context-sensitive criteria of appropriate functioning, captured as "AI trustworthiness." We further argue that the AIA does not provide an internal, audi...

AuthorsAndrea Ferrario
Primary categorycs.CY
Published17 April 2026
Last updated at source4 July 2026
cs.CYcs.AIcs.LG
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