From Legal Text to AI-specific Risk Sources: A Systematic Analysis of the EU AI Act's High-Risk Requirements

Ronald Schnitzer; Mike Auer; Rumpa Choudhury; Andreas Hapfelmeier; Maximilian Hoeving; Isabelle Painter; Josiane Xavier Parreira; Sonja Zillner

arXiv · 2609.13535

From Legal Text to AI-specific Risk Sources: A Systematic Analysis of the EU AI Act's High-Risk Requirements

Ronald Schnitzer·Mike Auer·Rumpa Choudhury·Andreas Hapfelmeier·Maximilian Hoeving·Isabelle Painter·Josiane Xavier Parreira·Sonja Zillner

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Abstract

The EU AI Act introduces mandatory requirements for high-risk AI systems with the explicit goal of ensuring the development and operation of trustworthy AI. At the same time, AI risk management practices rely on structured risk taxonomies to systematically identify and treat AI-specific risk sources. As both the AI Act and established risk taxonomies aim to address AI-induced risks, a natural question is whether they align in the risk sources they cover. However, no clear mapping exists between the risks implicitly addressed by the Act's high-risk requirements and established taxonomies, leaving practitioners without a structured basis for aligning regulatory obligations with AI risk management practice. This paper presents a systematic classification of the requirements extracted from the EU AI Act Section 2 (Requirements for high-risk AI systems), revealing that only a minority directly address AI-specific risk sources, while the majority impose organizational process and documentation obligations. From the AI risk-related requirements, a consolidated list of distinct AI-specific risk sources is derived. The resulting EU AI Act Risk Source List takes an important step towards bridging the gap between legal obligation and AI risk management practice, providing a structured reference for explicit comparison between existing AI risk taxonomies and the risk sources implicitly addressed by the EU AI Act. Important Note: This is the authors' preprint. The paper was presented at the 4th International Conference on Frontiers of Artificial Intelligence, Ethics, and Multidisciplinary Applications. A link to the conference's official proceedings will be provided upon publication.

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Ronald Schnitzer, Mike Auer, Rumpa Choudhury, Andreas Hapfelmeier, Maximilian Hoeving, Isabelle Painter, Josiane Xavier Parreira, Sonja Zillner. 2026-09-11. From Legal Text to AI-specific Risk Sources: A Systematic Analysis of the EU AI Act's High-Risk Requirements. https://arxiv.org/abs/2609.13535

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