AI Act and agentic systems
An AI agent needs a clear role, boundary and accountable owner
The word agent does not determine the legal risk of a system. Documentation needs to describe the technology and the concrete use case separately.
Current DUBSAR status
Evidence support, not legal classification
DUBSAR can help organise technical and operational evidence. It does not classify a system legally or certify compliance with the EU AI Act.
AI Act and agentic systems
Describe the agent before assessing its risk
A useful record identifies the agent's role, tools, model routes, permissions, data classes, intended users and responsible owner. It also describes what the agent cannot do without human authorisation.
This technical description remains distinct from legal classification. Intended purpose and the criteria in Article 6 and Annexes I and III drive high-risk classification; the organisation's role then affects which obligations apply.
- Agent role and intended purpose
- Allowed tools, data and model routes
- Human escalation and stop conditions
- Versioned policy and evidence references
AI Act and agentic systems
Make AI assistance and human review visible
Reports should distinguish an AI-generated draft from a human-reviewed or human-approved result. Model provenance, execution time and reviewer identity help explain how the output was produced.
The distinction is useful operationally even where a particular transparency obligation does not apply.
AI Act and agentic systems
Keep facts, hypotheses and gaps separate
Agentic workflows change quickly. A defensible dossier records the observed version and evidence rather than treating assumptions as permanent facts.
Missing documentation from a model or tool provider should be recorded as a gap, not silently replaced with an inference.
External sources
Check the official sources and current product claims.
Frequently asked questions
What to know before going further.
Are all AI agents high-risk systems under the EU AI Act?
No. Risk depends on the concrete use case, affected people and the organisation's legal role, not on the use of agentic technology alone.
Can DUBSAR perform the legal classification?
No. It can structure evidence for competent reviewers, but legal classification remains outside the product's authority.
Read next
Continue with another DUBSAR guide.
The portal remains in private testing. These guides explain what DUBSAR is proving — and what it does not yet claim.