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Interview question · AI Governance, Risk & Compliance

What are the EU AI Act risk tiers, and what must a high-risk provider do?

Tiers are decided by use, not by model. And for high-risk providers, Article 15 makes AI security a legal requirement.

mediumEssentialNewPreparation tags: JPMorgan Chase, Microsoft, SalesforceUpdated Nov 2026

TL;DR: Prohibited practices are banned (for example social scoring, manipulation causing significant harm, untargeted facial-image scraping). High-risk systems are safety components of regulated products (Annex I) or listed uses (Annex III: biometrics, critical infrastructure, education, employment, essential services and credit, law enforcement, migration, justice). Transparency duties apply to chatbots and synthetic content. Everything else is minimal risk. A high-risk provider must run a risk management system, ensure data governance, produce technical documentation, enable logging, give instructions for use, design for human oversight, ensure accuracy, robustness and cybersecurity, operate a quality management system, pass conformity assessment, affix CE marking, register, and do post-market monitoring and serious-incident reporting.

How to approach it

Explain classification by intended use, list the tiers with examples, then go through high-risk provider obligations translated into engineering work, and close with dates after the 2026 Digital Omnibus.

A strong answer

FIG · EU AI ACT RISK TIERS · OBLIGATIONS SCALE WITH RISK
High-risk providers carry the heaviest duties
  1. 1

    1 · Prohibited

    Banned practices

    • Social scoring, harmful manipulation, untargeted face scraping
  2. 2

    2 · High-risk

    Annex I products, Annex III uses

    • Risk management, data governance, documentation, logging
    • Human oversight, accuracy, robustness, cybersecurity, conformity assessment
  3. 3

    3 · Transparency

    Chatbots and synthetic content

    • Tell users; mark generated outputs
  4. 4

    4 · Minimal

    Everything else

    • Voluntary codes

Classification is by intended purpose. The same model can be minimal risk in a writing assistant and high-risk in a hiring tool. Annex III uses can escape high-risk classification if the system performs only narrow procedural or preparatory tasks and does not materially influence decisions, but systems that profile individuals remain high-risk; providers must document that assessment.

High-risk provider obligations.

ObligationEngineering form
Risk management system (Art. 9)Lifecycle risk process: threat models, evaluations, mitigations, residual risk
Data and data governance (Art. 10)Documented, relevant, representative datasets; bias examination and mitigation
Technical documentation (Art. 11, Annex IV)Design, data, training, evaluation, monitoring documentation
Record-keeping (Art. 12)Automatic event logs over the lifetime
Transparency to deployers (Art. 13)Instructions for use: capabilities, limitations, accuracy, oversight measures
Human oversight (Art. 14)Ability to understand, monitor, override and stop
Accuracy, robustness, cybersecurity (Art. 15)Declared metrics; resilience; protection against data poisoning, model poisoning, adversarial examples, confidentiality attacks
Quality management system (Art. 17)Processes for compliance, design control, testing, data management, incident handling
Conformity assessment, CE marking, EU declaration, registrationPre-market procedures and database registration
Post-market monitoring and serious incident reportingMonitoring plan; incident reporting to authorities

Deployers of high-risk systems have their own duties: use per instructions, human oversight by competent people, monitoring, keeping logs, informing affected workers, and for some deployers a fundamental rights impact assessment.

Timing (checked November 2026). The Digital Omnibus (Regulation (EU) 2026/1744) moved Annex III high-risk obligations to 2 December 2027 and Annex I obligations to 2 August 2028. Prohibitions have applied since 2 February 2025 and GPAI model obligations since 2 August 2025.

What interviewers probe next

  • "Is a customer-service chatbot high-risk?" Usually not; it has transparency duties. It becomes high-risk if it decides access to essential services, credit or similar.
  • "How does Article 15 change your security programme?" It turns AI-specific attack resilience into a documented legal requirement for high-risk systems: threat models, testing and controls for poisoning, adversarial inputs and confidentiality attacks.
  • "What makes a deployer become a provider?" Putting its name on the system, making a substantial modification, or changing its intended purpose so it becomes high-risk.

What if?

What if · interview follow-ups

Hold your answer as the constraints change

A startup offers two products in the EU: an AI system that screens job applicants and a customer service chatbot.

  1. Start here

    What are the risk tiers?

How it's scored

Weak: Lists tiers vaguely, or classifies by model type.

Hire: Correct tiers with examples, classification by intended purpose, and the main provider obligations.

Strong Hire: Translates obligations into engineering artefacts, highlights Article 15, covers deployer duties, the Annex III exception, role changes and current dates.

Common mistakes

  • Calling every LLM application high-risk.
  • Ignoring deployer obligations.
  • Quoting the original 2026 high-risk date as current.
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