Assess whether the retraining and refund function: Assuming EU AI Act duties apply, which approach best

A changed purpose and autonomous refund function require assessing whether modification alters provider responsibilities under the EU AI Act.

The question

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1. Treat all retraining as substantial modification requiring provider reclassification.

   Retraining alone does not establish substantial modification; the facts and resulting purpose or functionality must be evaluated.
2. Classify the change only by measuring accuracy against the vendor baseline.

   Accuracy comparison may inform evaluation but cannot alone determine whether intended purpose or statutory responsibilities changed substantially.
3. Assess whether the retraining and refund function substantially change purpose or responsibilities. ✓

   A changed intended purpose or substantial modification can affect provider responsibilities, so both the modification and resulting function require assessment.
4. Keep the vendor’s original role allocation because retraining is internal.

   Internal retraining combined with a changed intended purpose may affect statutory responsibilities, even when the vendor supplied the base model.

How to remember it

A changed purpose and autonomous refund function require assessing whether modification alters provider responsibilities under the EU AI Act.

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