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    High-Risk • Annex III

    EU AI Act for
    Education & EdTech

    AI in admissions, grading, and student assessment is high-risk under Annex III. Educational institutions and EdTech providers must prepare for deployer obligations.

    GDPR CompliantSOC 2 Type IIISO 27001

    Emotion Recognition Prohibited

    Article 5 prohibits AI systems that infer emotions in educational settings. This ban applied from 2 February 2025. Engagement monitoring through emotional analysis is generally not permitted.

    Education AI Use Cases

    AI in Admissions Decisions

    High-Risk

    AI used to determine access to educational institutions falls under Annex III high-risk.

    Key Obligations:

    • Article 26 deployer obligations
    • Human oversight for final decisions
    • Transparency to applicants
    • Non-discrimination monitoring

    Student Assessment & Grading

    High-Risk

    AI systems that assess or score students for educational purposes.

    Key Obligations:

    • Human review capability
    • Explainability of scoring
    • Appeals process
    • Logging of decisions

    Exam Proctoring

    High-Risk

    AI-powered proctoring systems that monitor students during exams.

    Key Obligations:

    • Transparency disclosure
    • Biometric data considerations
    • Student notification
    • Human review of flags

    Learning Management & Tutoring

    Limited Risk

    AI tutors and adaptive learning systems that don't make consequential decisions.

    Key Obligations:

    • Transparency if AI interaction
    • Mark AI-generated content
    • Student data protection

    Frequently Asked Questions

    Is AI used in student grading high-risk?

    Yes. AI systems used for assessing students and determining educational outcomes are explicitly high-risk under Annex III. This includes automated essay scoring, exam grading, and performance evaluation systems.

    What about AI tutoring systems?

    AI tutors that provide learning support without making consequential decisions are typically limited risk. However, transparency obligations apply if students interact with AI, and synthetic content must be marked.

    Do universities need to comply with the EU AI Act?

    Yes. Educational institutions deploying AI systems fall under deployer obligations. Public universities may also need to complete FRIAs for high-risk AI and register in the EU database.

    What about emotion recognition in education?

    Emotion recognition in educational settings is prohibited under Article 5 with very limited exceptions. Monitoring student emotions during learning is generally banned.

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