EU AI Act Risk Classifier

Fine-tuned DistilBERT model that classifies AI system descriptions into EU AI Act risk tiers.

Intended Use

Classifies a natural-language description of an AI system into one of five categories:

  • minimal_risk
  • limited_risk
  • high_risk
  • prohibited_risk
  • review (flagged for human review β€” description is ambiguous or spans multiple tiers)

Out of scope: This model does not provide legal advice and should not be used as the sole basis for a compliance decision.

Training Data

  • Dataset size: 1,538 labeled examples
  • Labels sourced via a dual-labeling pipeline with human review on flagged conflicts
  • Ambiguous/boundary-testing "review" cases which require human review.

Training Procedure

  • Base model: distilbert-base-uncased
  • Learning rate: 3e-5
  • Epochs: 10 - 20
  • Batch size: 8
  • Max sequence length: 256

Evaluation Results

Metric Score
Accuracy 92.08%
Macro F1 0.9209

Per-class F1:

Class F1
minimal_risk 0.97
limited_risk 0.93
high_risk 0.91
prohibited_risk 0.93
review 0.84

Limitations

  • The "review" class has the lowest F1, the model is least confident distinguishing genuinely ambiguous cases, which is expected since these cases are excluded from training by design.
  • High Risk and Limited Risk are the most frequently confused pair among the four primary tiers, particularly at the boundary between Annex III decision-influencing systems and Article 50 transparency-only systems.

Ethical Considerations / Risks

  • The training labels came from an LLM-assisted first pass, then a decision tree based second pass, then a human reviewer.
  • The results of the model are not intended to provide legal advice

Version History/Release Notes

v1.0 β€” 2026-08-14

  • Initial release
  • Trained on 1,538 labeled examples across 5 tiers: minimal_risk, limited_risk, high_risk, prohibited_risk, review
  • Labels produced via a dual-pipeline: AI-assisted first pass β†’ decision-tree second pass β†’ human review, with conflicts between the two automated passes flagged for review
  • Accuracy: 92.08% Β· Macro F1: 0.9209
  • Per-class F1: minimal_risk 0.97, limited_risk 0.93, high_risk 0.91, prohibited_risk 0.93, review 0.84
  • Known limitation: review has the lowest F1 of the five classes β€” expected, since ambiguous cases are excluded from confident training signal by design. High Risk / Limited Risk is the most frequently confused pair among the four primary tiers, particularly at the Annex III (decision-influencing) vs. Article 50 (transparency-only) boundary.
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