AI Act: is a voter exposed to the output of a campaign tool whose recommended messages staff send on?

Annex III, point 8(b), excludes AI systems to the output of which natural persons are not directly exposed. A campaign tool ranks voters and recommends which message each voter should receive; campaign staff then send those messages. The text does not say whether this counts as direct exposure to the output of the system, read with recital 62.

Consequence

Whether the campaign tool falls under point 8(b) depends on whether the voter counts as directly exposed to its output: the internal ranking or the message the voter receives.

Proposed correction

The guidelines could say whether mediated exposure of this kind is direct exposure.

Jurisdiction

European Union — European Union

Act

Regulation (EU) 2024/1689 (Artificial Intelligence Act)

Place

Annex III, point 8(b)

Record

Question of reading or data

Class

Question of reading or data

Where it arose

The text of the act

Arxo's conclusion

Confirmed

Official text

Unchanged at last check

Last checked

2026-10-31

Evidence

Reproduced by execution. Quotations are verbatim from the official material; translations are ours and marked.

AI systems to the output of which natural persons are not directly exposed

How to check it without Arxo's tools

1. Open Regulation (EU) 2024/1689 (Artificial Intelligence Act), Official Journal, 12 July 2024, English version and find Annex III, point 8(b) (English). Compare the text with the quotation above. A copy is kept in this register: 8f0b656302f9864c-en.xhtml (SHA-256 8f0b656302f9864cc87e040c371f209a9d65ae1a6cecc25ca5eb737e872d721a, copy of the official file).
2. The finding holds if the quoted passages read as shown and the comparison gives the result stated at the top of this page. If it does not, write to us with the record ID.

How this finding was made

AI models helped read and compare the texts and review the draft letters. AI models also helped build the illustrative rule models.

Responsible institutions

• European Commission, European AI Office — applies the Regulation and prepares the Commission's guidelines

Reported to

Responses

No response recorded.

History

1. 2026-10-31Confirmed by Arxo
2. 2026-10-31Entered in the register
3. 2026-10-31Reported to European Commission, European AI Office (e-mail)

Cite this record

Arxo Law, Arxo Findings Register, ARXO-2026-0428, https://arxo.io/findings/ARXO-2026-0428/ (status as of 2026-10-31). Data: ARXO-2026-0428.json.