Defining AI Systems: Insights from the European Commission’s New Guidelines

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Is Your Technology Really an AI System? Here’s What the EU Says ​

With AI becoming an integral part of modern businesses, the question isn’t just about how to use AI—but whether your system even qualifies as one under the law. On February 6, 2025, the European Commission released new guidelines clarifying what constitutes an AI system under the EU AI Act. For businesses navigating compliance, understanding this definition is crucial.

Why this matters? ​

If your product is labeled as an AI system, it could face strict regulations, especially if it’s high-risk or engages in prohibited practices. Misclassifying your system could mean non-compliance, leading to fines or legal issues. But what exactly makes a system an “AI system” under the EU AI Act? Let’s break it down.

The below image identifies the seven key elements that define an AI system under Article 3(1) of the EU AI Act. 

What’s Not Considered an AI System?

Not all machine-based systems fall under the AI umbrella. According to their guidelines, the following are excluded:

  • Basic Data Processing: Systems that perform tasks based on predefined rules without learning or reasoning, such as database management systems
  • Classical Heuristics: Problem-solving methods relying on rule-based approaches without data-driven learning.
  • Simple Prediction Systems: Systems using basic statistical methods like averages for predictions without complex pattern analysis.
  • Optimization Systems: Systems improving computational efficiency without intelligent decision-making adjustments, e.g., resource allocation in satellite communications.

Implications for Businesses ​ ​

These guidelines clarify which systems are subject to the EU AI Act’s regulatory obligations, including:

  • Prohibited Practices (Article 5): Systems engaging in manipulative or discriminatory practices.
  • High-Risk AI Systems (Article 6): Those impacting safety or fundamental rights.
  • Transparency Requirements (Article 50): Specific requirements for systems interacting with humans or generating deepfakes. 

Are You Compliant? Find Out with EthiAI ​​ ​

Understanding these definitions is the first step. But ensuring compliance can be complex. That’s where EthiAI comes in. Our advanced quiz-based risk assessment system helps you evaluate whether your AI system meets the EU AI Act’s requirements. Don’t wait for penalties—assess your risks now at EthiAI. 

AUTHORED BY
Jayasri A

Junior AI Engineer

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