Eight questions on role, establishment, Annex III match, Annex I product, the Art. 6(3) filter, Art. 50 functions and general-purpose AI. Every rule below is evaluated against the answers; a rule that matches adds a tier candidate, an obligation profile from profiles.json and notes. The highest tier in the profiles tierOrder becomes the result tier. The result is a reasoned technical assessment for discussion with counsel; it is not a classification decision under Art. 6 and not a conformity assessment.
Questions
Classifier questions
Id
Prompt
Type
Shown when
Options
role
Which role does your organisation take for this AI system or model?The roles are defined in Art. 3(3) to 3(8). A product manufacturer that places an AI system on the market together with its product under its own name is treated as the provider under Art. 25(3).
single
always
provider Provider: we develop it, or have it developed, and place it on the market or put it into service under our own name (Art. 3(3))
manufacturer Product manufacturer: we embed an AI system in a product placed on the market under our own name (Art. 25(3))
deployer Deployer: we use it under our own authority in a professional activity (Art. 3(4))
importer Importer: we place a system from a provider established outside the Union on the Union market (Art. 3(6))
distributor Distributor: we make a system available on the Union market without being its provider or importer (Art. 3(7))
gpai-provider General-purpose AI model provider: we place a general-purpose AI model on the market, including after a modification that makes us its provider (Art. 3(63), Art. 53)
est
Is your organisation established or located in the Union?Art. 2(1) applies the Act to providers placing systems on the Union market wherever they are established, and to providers and deployers in a third country where the output is used in the Union. A provider outside the Union appoints an authorised representative under Art. 22 (high-risk systems) or Art. 54 (general-purpose AI models).
single
always
eu Yes, established in the Union
non-eu No, established outside the Union
a3
Does the intended purpose of the system fall within an Annex III area?Annex III lists eight areas. Art. 6(2) classifies a system referred to in Annex III as high-risk unless Art. 6(3) applies.
single
role in [provider, manufacturer, deployer, importer, distributor]
none No Annex III area matches
biometrics Annex III point 1: remote biometric identification, biometric categorisation by sensitive attributes, or emotion recognition
critical-infrastructure Annex III point 2: safety component in the management or operation of critical digital infrastructure, road traffic, or the supply of water, gas, heating or electricity
education Annex III point 3: education and vocational training (access, admission, evaluation, proctoring)
employment Annex III point 4: employment, workers management and access to self-employment (recruitment, selection, task allocation, monitoring, evaluation)
essential-services Annex III point 5: access to essential private and public services (benefits, creditworthiness, life and health insurance risk and pricing, emergency dispatch and triage)
law-enforcement Annex III point 6: law enforcement
migration Annex III point 7: migration, asylum and border control management
justice-democracy Annex III point 8: administration of justice and democratic processes
a1
Is the system a safety component of a product, or itself a product, covered by the Union harmonisation legislation listed in Annex I?Section A lists New Legislative Framework acts (for example toys, lifts, radio equipment, pressure equipment, PPE, medical devices, in vitro diagnostics); a system under one of them is high-risk under Art. 6(1) where that act requires third-party conformity assessment. Section B lists sectoral acts (civil aviation, vehicles, marine equipment, rail, agricultural vehicles and, after Regulation (EU) 2026/1744, machinery under Regulation (EU) 2023/1230); under Art. 2(2) those products follow their sectoral route.
single
role in [provider, manufacturer, deployer, importer, distributor]
none No Annex I legislation covers the product
section-a Annex I Section A act, and that act requires a third-party conformity assessment for the product
section-a-self Annex I Section A act, but that act allows the manufacturer to self-assess the product
section-b Annex I Section B act (aviation, vehicles, marine equipment, rail, agricultural vehicles, machinery)
c63
Does one of the Art. 6(3) conditions apply, and does the system profile natural persons?Art. 6(3) removes an Annex III system from the high-risk class where it does not pose a significant risk of harm because it performs a narrow procedural task, improves the result of a previously completed human activity, detects decision-making patterns without replacing or influencing the human assessment without proper human review, or performs a preparatory task. The last subparagraph of Art. 6(3) keeps a system high-risk in every case where it performs profiling of natural persons.
single
a3 ≠ none
none No Art. 6(3) condition applies
condition One of the Art. 6(3)(a) to (d) conditions applies, and the system does not profile natural persons
profiling The system performs profiling of natural persons (Art. 6(3), last subparagraph)
a50
Which Art. 50 functions does the system perform?Art. 50(1) covers systems intended to interact with natural persons; Art. 50(2) covers systems that generate synthetic audio, image, video or text; Art. 50(3) covers emotion recognition and biometric categorisation systems; Art. 50(4) covers deep fakes and AI-generated text published to inform the public on matters of public interest.
multi
role in [provider, manufacturer, deployer, importer, distributor]
interact Interacts directly with natural persons (Art. 50(1))
synthetic Generates synthetic audio, image, video or text (Art. 50(2))
emotion-biometric Emotion recognition or biometric categorisation (Art. 50(3))
deepfake-text Generates or manipulates deep fakes, or text published to inform the public on matters of public interest (Art. 50(4))
dk
Is the deployer a body governed by public law, a private entity providing public services, or a deployer of an Annex III point 5(b) or 5(c) system?Art. 27(1) limits the fundamental rights impact assessment to these deployers. Point 5(b) covers creditworthiness evaluation and credit scoring; point 5(c) covers risk assessment and pricing for life and health insurance.
single
role = deployer and a3 ≠ none
yes Yes, one of these applies
no No
compute
Does the model meet the Art. 51 systemic-risk trigger?Art. 51(2) presumes high-impact capabilities where the cumulative training compute exceeds 10^25 floating point operations. Art. 51(1)(b) covers a Commission designation. The Commission guidelines on the scope of the general-purpose AI obligations, listed on the standards page with their status, describe when a modification of a third party's model makes the modifier a provider.
single
role = gpai-provider
no No: below the Art. 51(2) compute threshold and not designated
yes Yes: above the Art. 51(2) compute threshold, or designated by the Commission under Art. 51(1)(b)
unknown Not yet established
Rules
Classifier rules
Rule
When
Tier
Profiles
Unsettled
Notes
provider-annex-iii-high-risk
role in [provider, manufacturer] and a3 ≠ none and c63 in [none, profiling]
The Art. 6(3) conclusion is documented under Art. 6(4) before placing on the market. The timing of the Art. 49(2) registration duty is an unsettled point; both readings are shown.
provider-annex-i-a
role in [provider, manufacturer] and a1 = section-a
The product is covered by an Annex I Section A act that requires third-party conformity assessment, so the system is high-risk under Art. 6(1).
provider-annex-i-a-self
role in [provider, manufacturer] and a1 = section-a-self
Art. 6(1)(b) requires a third-party conformity assessment under the Section A act for the system to be high-risk on that ground; a self-assessed product does not meet it. The Annex III test above still applies.
provider-annex-i-b
role in [provider, manufacturer] and a1 = section-b
Under Art. 2(2), a product covered by Annex I Section B follows its sectoral legislation; only Art. 6(1), Art. 60a and Art. 102 to 112 apply directly; Art. 57 to 59 apply where the sectoral legislation integrates the high-risk requirements.
deployer-annex-iii
role = deployer and a3 ≠ none and c63 in [none, profiling]
The Art. 51(2) presumption turns on cumulative training compute; the classification protocol records the compute estimate and its method before the Art. 55 duties are assessed.
non-eu-provider-annex-iii
role in [provider, manufacturer] and est = non-eu and a3 ≠ none and c63 in [none, profiling]
{
"id": "classifier",
"version": "1.0",
"title": "Risk and role classifier",
"summary": "Eight questions on role, establishment, Annex III match, Annex I product, the Art. 6(3) filter, Art. 50 functions and general-purpose AI. Every rule below is evaluated against the answers; a rule that matches adds a tier candidate, an obligation profile from profiles.json and notes. The highest tier in the profiles tierOrder becomes the result tier. The result is a reasoned technical assessment for discussion with counsel; it is not a classification decision under Art. 6 and not a conformity assessment.",
"derivedFrom": [
"PR-CLS"
],
"resultLabel": "Reasoned technical assessment for discussion with counsel",
"questions": [
{
"id": "role",
"prompt": "Which role does your organisation take for this AI system or model?",
"help": "The roles are defined in Art. 3(3) to 3(8). A product manufacturer that places an AI system on the market together with its product under its own name is treated as the provider under Art. 25(3).",
"type": "single",
"options": [
{
"value": "provider",
"label": "Provider: we develop it, or have it developed, and place it on the market or put it into service under our own name (Art. 3(3))"
},
{
"value": "manufacturer",
"label": "Product manufacturer: we embed an AI system in a product placed on the market under our own name (Art. 25(3))"
},
{
"value": "deployer",
"label": "Deployer: we use it under our own authority in a professional activity (Art. 3(4))"
},
{
"value": "importer",
"label": "Importer: we place a system from a provider established outside the Union on the Union market (Art. 3(6))"
},
{
"value": "distributor",
"label": "Distributor: we make a system available on the Union market without being its provider or importer (Art. 3(7))"
},
{
"value": "gpai-provider",
"label": "General-purpose AI model provider: we place a general-purpose AI model on the market, including after a modification that makes us its provider (Art. 3(63), Art. 53)"
}
]
},
{
"id": "est",
"prompt": "Is your organisation established or located in the Union?",
"help": "Art. 2(1) applies the Act to providers placing systems on the Union market wherever they are established, and to providers and deployers in a third country where the output is used in the Union. A provider outside the Union appoints an authorised representative under Art. 22 (high-risk systems) or Art. 54 (general-purpose AI models).",
"type": "single",
"options": [
{
"value": "eu",
"label": "Yes, established in the Union"
},
{
"value": "non-eu",
"label": "No, established outside the Union"
}
]
},
{
"id": "a3",
"prompt": "Does the intended purpose of the system fall within an Annex III area?",
"help": "Annex III lists eight areas. Art. 6(2) classifies a system referred to in Annex III as high-risk unless Art. 6(3) applies.",
"type": "single",
"showWhen": {
"role": [
"provider",
"manufacturer",
"deployer",
"importer",
"distributor"
]
},
"options": [
{
"value": "none",
"label": "No Annex III area matches"
},
{
"value": "biometrics",
"label": "Annex III point 1: remote biometric identification, biometric categorisation by sensitive attributes, or emotion recognition"
},
{
"value": "critical-infrastructure",
"label": "Annex III point 2: safety component in the management or operation of critical digital infrastructure, road traffic, or the supply of water, gas, heating or electricity"
},
{
"value": "education",
"label": "Annex III point 3: education and vocational training (access, admission, evaluation, proctoring)"
},
{
"value": "employment",
"label": "Annex III point 4: employment, workers management and access to self-employment (recruitment, selection, task allocation, monitoring, evaluation)"
},
{
"value": "essential-services",
"label": "Annex III point 5: access to essential private and public services (benefits, creditworthiness, life and health insurance risk and pricing, emergency dispatch and triage)"
},
{
"value": "law-enforcement",
"label": "Annex III point 6: law enforcement"
},
{
"value": "migration",
"label": "Annex III point 7: migration, asylum and border control management"
},
{
"value": "justice-democracy",
"label": "Annex III point 8: administration of justice and democratic processes"
}
]
},
{
"id": "a1",
"prompt": "Is the system a safety component of a product, or itself a product, covered by the Union harmonisation legislation listed in Annex I?",
"help": "Section A lists New Legislative Framework acts (for example toys, lifts, radio equipment, pressure equipment, PPE, medical devices, in vitro diagnostics); a system under one of them is high-risk under Art. 6(1) where that act requires third-party conformity assessment. Section B lists sectoral acts (civil aviation, vehicles, marine equipment, rail, agricultural vehicles and, after Regulation (EU) 2026/1744, machinery under Regulation (EU) 2023/1230); under Art. 2(2) those products follow their sectoral route.",
"type": "single",
"showWhen": {
"role": [
"provider",
"manufacturer",
"deployer",
"importer",
"distributor"
]
},
"options": [
{
"value": "none",
"label": "No Annex I legislation covers the product"
},
{
"value": "section-a",
"label": "Annex I Section A act, and that act requires a third-party conformity assessment for the product"
},
{
"value": "section-a-self",
"label": "Annex I Section A act, but that act allows the manufacturer to self-assess the product"
},
{
"value": "section-b",
"label": "Annex I Section B act (aviation, vehicles, marine equipment, rail, agricultural vehicles, machinery)"
}
]
},
{
"id": "c63",
"prompt": "Does one of the Art. 6(3) conditions apply, and does the system profile natural persons?",
"help": "Art. 6(3) removes an Annex III system from the high-risk class where it does not pose a significant risk of harm because it performs a narrow procedural task, improves the result of a previously completed human activity, detects decision-making patterns without replacing or influencing the human assessment without proper human review, or performs a preparatory task. The last subparagraph of Art. 6(3) keeps a system high-risk in every case where it performs profiling of natural persons.",
"type": "single",
"showWhen": {
"a3": {
"not": "none"
}
},
"options": [
{
"value": "none",
"label": "No Art. 6(3) condition applies"
},
{
"value": "condition",
"label": "One of the Art. 6(3)(a) to (d) conditions applies, and the system does not profile natural persons"
},
{
"value": "profiling",
"label": "The system performs profiling of natural persons (Art. 6(3), last subparagraph)"
}
]
},
{
"id": "a50",
"prompt": "Which Art. 50 functions does the system perform?",
"help": "Art. 50(1) covers systems intended to interact with natural persons; Art. 50(2) covers systems that generate synthetic audio, image, video or text; Art. 50(3) covers emotion recognition and biometric categorisation systems; Art. 50(4) covers deep fakes and AI-generated text published to inform the public on matters of public interest.",
"type": "multi",
"showWhen": {
"role": [
"provider",
"manufacturer",
"deployer",
"importer",
"distributor"
]
},
"options": [
{
"value": "interact",
"label": "Interacts directly with natural persons (Art. 50(1))"
},
{
"value": "synthetic",
"label": "Generates synthetic audio, image, video or text (Art. 50(2))"
},
{
"value": "emotion-biometric",
"label": "Emotion recognition or biometric categorisation (Art. 50(3))"
},
{
"value": "deepfake-text",
"label": "Generates or manipulates deep fakes, or text published to inform the public on matters of public interest (Art. 50(4))"
}
]
},
{
"id": "dk",
"prompt": "Is the deployer a body governed by public law, a private entity providing public services, or a deployer of an Annex III point 5(b) or 5(c) system?",
"help": "Art. 27(1) limits the fundamental rights impact assessment to these deployers. Point 5(b) covers creditworthiness evaluation and credit scoring; point 5(c) covers risk assessment and pricing for life and health insurance.",
"type": "single",
"showWhen": {
"role": "deployer",
"a3": {
"not": "none"
}
},
"options": [
{
"value": "yes",
"label": "Yes, one of these applies"
},
{
"value": "no",
"label": "No"
}
]
},
{
"id": "compute",
"prompt": "Does the model meet the Art. 51 systemic-risk trigger?",
"help": "Art. 51(2) presumes high-impact capabilities where the cumulative training compute exceeds 10^25 floating point operations. Art. 51(1)(b) covers a Commission designation. The Commission guidelines on the scope of the general-purpose AI obligations, listed on the standards page with their status, describe when a modification of a third party's model makes the modifier a provider.",
"type": "single",
"showWhen": {
"role": "gpai-provider"
},
"options": [
{
"value": "no",
"label": "No: below the Art. 51(2) compute threshold and not designated"
},
{
"value": "yes",
"label": "Yes: above the Art. 51(2) compute threshold, or designated by the Commission under Art. 51(1)(b)"
},
{
"value": "unknown",
"label": "Not yet established"
}
]
}
],
"rules": [
{
"id": "provider-annex-iii-high-risk",
"when": {
"role": [
"provider",
"manufacturer"
],
"a3": {
"not": "none"
},
"c63": [
"none",
"profiling"
]
},
"tier": "high-risk-annex-iii",
"profiles": [
"provider-high-risk-annex-iii"
],
"notes": [
"The system is referred to in Annex III and no Art. 6(3) condition removes it from the high-risk class (Art. 6(2))."
]
},
{
"id": "provider-annex-iii-profiling",
"when": {
"role": [
"provider",
"manufacturer"
],
"a3": {
"not": "none"
},
"c63": "profiling"
},
"notes": [
"Profiling of natural persons keeps the system high-risk in every case (Art. 6(3), last subparagraph)."
]
},
{
"id": "provider-art-6-3",
"when": {
"role": [
"provider",
"manufacturer"
],
"a3": {
"not": "none"
},
"c63": "condition"
},
"tier": "not-high-risk-art-6-3",
"profiles": [
"provider-not-high-risk-art-6-3"
],
"unsettled": [
"art6-3-registration"
],
"notes": [
"The Art. 6(3) conclusion is documented under Art. 6(4) before placing on the market. The timing of the Art. 49(2) registration duty is an unsettled point; both readings are shown."
]
},
{
"id": "provider-annex-i-a",
"when": {
"role": [
"provider",
"manufacturer"
],
"a1": "section-a"
},
"tier": "high-risk-annex-i-a",
"profiles": [
"provider-high-risk-annex-i-a"
],
"notes": [
"The product is covered by an Annex I Section A act that requires third-party conformity assessment, so the system is high-risk under Art. 6(1)."
]
},
{
"id": "provider-annex-i-a-self",
"when": {
"role": [
"provider",
"manufacturer"
],
"a1": "section-a-self"
},
"notes": [
"Art. 6(1)(b) requires a third-party conformity assessment under the Section A act for the system to be high-risk on that ground; a self-assessed product does not meet it. The Annex III test above still applies."
]
},
{
"id": "provider-annex-i-b",
"when": {
"role": [
"provider",
"manufacturer"
],
"a1": "section-b"
},
"tier": "annex-i-b",
"profiles": [
"provider-annex-i-b"
],
"notes": [
"Under Art. 2(2), a product covered by Annex I Section B follows its sectoral legislation; only Art. 6(1), Art. 60a and Art. 102 to 112 apply directly; Art. 57 to 59 apply where the sectoral legislation integrates the high-risk requirements."
]
},
{
"id": "deployer-annex-iii",
"when": {
"role": "deployer",
"a3": {
"not": "none"
},
"c63": [
"none",
"profiling"
]
},
"tier": "high-risk-annex-iii",
"profiles": [
"deployer-high-risk-annex-iii"
]
},
{
"id": "deployer-fria",
"when": {
"role": "deployer",
"a3": {
"not": "none"
},
"c63": [
"none",
"profiling"
],
"dk": "yes"
},
"profiles": [
"deployer-fria"
],
"unsettled": [
"fria-timing"
],
"notes": [
"Art. 27(1) applies to this deployer; the applicability date of the FRIA duty is an unsettled point and both readings are shown."
]
},
{
"id": "deployer-annex-i-a",
"when": {
"role": "deployer",
"a1": "section-a"
},
"tier": "high-risk-annex-i-a",
"profiles": [
"deployer-high-risk-annex-i-a"
]
},
{
"id": "deployer-art-6-3",
"when": {
"role": "deployer",
"a3": {
"not": "none"
},
"c63": "condition"
},
"tier": "not-high-risk-art-6-3",
"profiles": [
"deployer-not-high-risk-art-6-3"
],
"unsettled": [
"art6-3-registration"
]
},
{
"id": "importer-annex-iii",
"when": {
"role": "importer",
"a3": {
"not": "none"
},
"c63": [
"none",
"profiling"
]
},
"tier": "high-risk-annex-iii",
"profiles": [
"importer-high-risk"
]
},
{
"id": "importer-annex-i-a",
"when": {
"role": "importer",
"a1": "section-a"
},
"tier": "high-risk-annex-i-a",
"profiles": [
"importer-high-risk-annex-i-a"
]
},
{
"id": "distributor-annex-iii",
"when": {
"role": "distributor",
"a3": {
"not": "none"
},
"c63": [
"none",
"profiling"
]
},
"tier": "high-risk-annex-iii",
"profiles": [
"distributor-high-risk"
]
},
{
"id": "distributor-annex-i-a",
"when": {
"role": "distributor",
"a1": "section-a"
},
"tier": "high-risk-annex-i-a",
"profiles": [
"distributor-high-risk-annex-i-a"
]
},
{
"id": "provider-art-50",
"when": {
"role": [
"provider",
"manufacturer",
"importer",
"distributor"
],
"a50": {
"includesAny": [
"interact",
"synthetic"
]
}
},
"tier": "transparency-art-50",
"profiles": [
"provider-art-50"
],
"notes": [
"Art. 50(1) and 50(2) place the disclosure and marking duties on the provider."
]
},
{
"id": "provider-art-50-synthetic",
"when": {
"role": [
"provider",
"manufacturer"
],
"a50": {
"includesAny": [
"synthetic"
]
}
},
"unsettled": [
"art50-technique-adequacy"
],
"notes": [
"Which marking technique satisfies Art. 50(2) is an unsettled point; both readings are shown."
]
},
{
"id": "deployer-art-50",
"when": {
"role": "deployer",
"a50": {
"includesAny": [
"emotion-biometric",
"deepfake-text"
]
}
},
"tier": "transparency-art-50",
"profiles": [
"deployer-art-50"
],
"notes": [
"Art. 50(3) and 50(4) place the disclosure duties on the deployer."
]
},
{
"id": "deployer-art-50-provider-side",
"when": {
"role": "deployer",
"a50": {
"includesAny": [
"interact",
"synthetic"
]
}
},
"notes": [
"Art. 50(1) and 50(2) are provider duties; a deployer verifies that the provider's disclosure and marking are present in the system it uses."
]
},
{
"id": "gpai",
"when": {
"role": "gpai-provider"
},
"tier": "gpai",
"profiles": [
"gpai-provider"
]
},
{
"id": "gpai-non-eu",
"when": {
"role": "gpai-provider",
"est": "non-eu"
},
"profiles": [
"gpai-provider-non-eu"
]
},
{
"id": "gpai-systemic",
"when": {
"role": "gpai-provider",
"compute": "yes"
},
"tier": "gpai-systemic-risk",
"profiles": [
"gpai-provider-systemic"
]
},
{
"id": "gpai-compute-unknown",
"when": {
"role": "gpai-provider",
"compute": "unknown"
},
"notes": [
"The Art. 51(2) presumption turns on cumulative training compute; the classification protocol records the compute estimate and its method before the Art. 55 duties are assessed."
]
},
{
"id": "non-eu-provider-annex-iii",
"when": {
"role": [
"provider",
"manufacturer"
],
"est": "non-eu",
"a3": {
"not": "none"
},
"c63": [
"none",
"profiling"
]
},
"profiles": [
"non-eu-provider-annex-iii"
]
},
{
"id": "non-eu-provider-annex-i-a",
"when": {
"role": [
"provider",
"manufacturer"
],
"est": "non-eu",
"a1": "section-a"
},
"profiles": [
"non-eu-provider-annex-i-a"
]
},
{
"id": "everyone-literacy",
"when": {},
"profiles": [
"all-literacy"
]
}
],
"queryParams": {
"role": "role",
"est": "est",
"a3": "a3",
"a1": "a1",
"c63": "c63",
"a50": "a50",
"dk": "dk",
"compute": "compute"
}
}