Whether the system is high-risk under the EU AI Act from explainability pack

Situation

A near-miss where an agent emailed a customer unreviewed put explainability pack for a denied-credit decision in front of HR analytics governance lead in a city using a hiring-screen algorithm. This AI Governance / Inventory and Regulatory Fit close is the system is high-risk from explainability pack for a denied-credit decision, and the live options are Policy or governance breach, Model defect, Dual failure.

Decision

HR analytics governance lead in a city using a hiring-screen algorithm must choose Policy or governance breach / Model defect / Dual failure / Hold for the missing fact using explainability pack for a denied-credit decision after a near-miss where an agent emailed a customer unreviewed.

Hypotheses to test

• Explainability pack for a denied-credit decision reads as Policy or governance breach once a near-miss where an agent emailed a customer unreviewed is lined up to the same AI Governance population.
• Explainability pack for a denied-credit decision is closer to Model defect after a near-miss where an agent emailed a customer unreviewed; Policy or governance breach would over-claim this Inventory and Regulatory Fit extract.
• Dual failure is still live in explainability pack for a denied-credit decision for HR analytics governance lead in a city using a hiring-screen algorithm.
• Explainability pack for a denied-credit decision is missing the fact HR analytics governance lead needs after a near-miss where an agent emailed a customer unreviewed; stop this AI Governance close.

Analysis required

• Reproduce the incident row in explainability pack for a denied-credit decision and say whether it ever touched production data.
• Split policy-or-governance failure from a model defect using prompts, outputs, and human edits in explainability pack for a denied-credit decision.
• Reproduce the incident row in explainability pack for a denied-credit decision and say whether it ever touched production data.
• For this AI Governance Inventory and Regulatory Fit file, read explainability pack for a denied-credit decision against a near-miss where an agent emailed a customer unreviewed and write the one fact that would move the system is high-risk for HR analytics governance lead.

Recommendation