Is This an AI System?
The first question in EU AI Act compliance: does your system even qualify as "AI"? Here's how to tell—with examples and edge cases.
The Official Definition
"A machine-based system that is designed to operate with varying levels of autonomy and that may exhibit adaptiveness after deployment, and that, for explicit or implicit objectives, infers, from the input it receives, how to generate outputs such as predictions, content, recommendations, or decisions that can influence physical or virtual environments."
— EU AI Act, Article 3(1)
Three Key Criteria
A system is likely an AI system if it meets all three criteria:
Infers outputs from inputs
The system generates predictions, recommendations, decisions, or content based on input data
Achieves explicit or implicit objectives
It's designed to accomplish specific goals—whether stated or learned
Operates with varying levels of autonomy
Functions with some independence, not purely manual rule execution
Examples: AI vs Not AI
Likely AI Systems
Likely Not AI Systems
Edge Cases & Grey Areas
When in doubt, document your reasoning
The Commission has published guidance to help interpret the definition. When a system is borderline, document your assessment with clear rationale. Our Definition Checker tool helps you do this systematically.
How to Document Your Decision
What to Record
- • System name and description
- • Assessment date and reviewer
- • Criteria evaluation (3 key questions)
- • Conclusion: AI system / Not AI / Needs review
- • Rationale for the decision
- • Confidence level (High/Medium/Low)
Use Our Checker Tool
Our AI Definition Checker walks you through the criteria and generates a documented assessment memo automatically.
Run Definition CheckerFrequently Asked Questions
What is the EU AI Act definition of an AI system?
Under the EU AI Act, an AI system is a machine-based system that infers from inputs to generate outputs (predictions, recommendations, decisions, or content) for explicit or implicit objectives, operating with varying levels of autonomy.
Why does the AI system definition matter?
If a system qualifies as an AI system under the Act, it triggers compliance obligations—from transparency requirements to high-risk controls. Systems outside the definition don't require AI Act compliance.
Are chatbots AI systems?
Most modern chatbots that use NLP or LLM technology are AI systems because they infer responses from input. Simple FAQ bots with fixed responses may not qualify.
Is RPA (Robotic Process Automation) an AI system?
Basic RPA that follows fixed rules is typically not an AI system. However, 'intelligent' RPA that uses ML to make decisions or adapt behavior likely qualifies.
How do we document our AI system determination?
Record the assessment date, reviewer, the criteria evaluated, your conclusion (AI system / not AI system / needs review), and the rationale. Klarvo's AI Definition Checker generates this documentation automatically.
Not Sure if Your System is AI?
Use our free Definition Checker tool to assess your systems and generate documentation.