Model-level obligations and downstream high-risk | AIGP
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Model-level obligations and downstream high-risk: Which allocation is most accurate?

AIGP Understanding How Laws, Standards and Frameworks Apply to AI Easy

General-purpose model obligations and downstream high-risk application duties are distinct and may apply to different actors.

The question

A housing administrator uses a general-purpose model inside an EU AI Act high-risk application that ranks applicants, assuming all relevant duties apply. Which allocation is most accurate?

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  1. The housing administrator has no duties if the model supplier supplies technical documentation.
    Supplier documentation supports downstream governance but does not remove duties arising from operating a high-risk housing application.
  2. Model-level obligations and downstream high-risk application duties must be analyzed separately. ✓
    The EU AI Act distinguishes general-purpose model obligations from obligations for high-risk systems and their responsible actors.
  3. The model provider’s general-purpose duties replace application-level obligations.
    General-purpose model obligations do not replace separate obligations attached to the downstream high-risk application and its deployer or provider roles.
  4. Only the housing administrator has duties because applicants see the application.
    The model provider may have general-purpose obligations, while application actors can have distinct high-risk system duties.
The trap
Analyze the model layer and application layer independently before assigning duties.

How to remember it

General-purpose model obligations and downstream high-risk application duties are distinct and may apply to different actors.

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