Arxo Findings Register · Arxo Law

ARXO-2026-0428 · Reported

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
Normative text · Regulation (EU) 2024/1689 (Artificial Intelligence Act), Official Journal, 12 July 2024, English version · Annex III, point 8(b) (English) · published · retrieved 2026-10-31 · SHA-256 8f0b656302f9864cc87e040c371f209a9d65ae1a6cecc25ca5eb737e872d721a · copy

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

Reported to

DateInstitutionChannelReference
2026-10-31European Commission, European AI Officee-mailMessage-ID: <CAH-SH70YM_AC_01zvysJGHJc08uAX6NxnU6XtfyeJT2hGLo=Gw@mail.gmail.com>

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.