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AIACT Research · Updated September 2026

AI agents regulation

AI agents are not a standalone legal risk category in the EU AI Act. Their obligations depend on the underlying system, intended purpose, capabilities, model and deployment context.

01

AI-system rules still apply

Agentic architecture does not remove the need to classify the system under ordinary AI Act definitions and risk routes.

02

Tool use matters

Autonomous access to software and external systems can increase practical impact and should be documented in risk assessment.

03

Transparency

Agents interacting with people or generating content can trigger Article 50 duties.

04

High-risk context

An agent used for a sensitive Annex III use case may fall into high-risk obligations when the relevant provisions apply.

05

GPAI systemic risk

Autonomous capabilities can be relevant to systemic-risk assessment for general-purpose models.

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