Assess whether the system is high-risk under the EU AI Act (7ca3f2)
August 31, 2026
SITUATION Board AI liaison owns this Policy and Oversight review in a retailer using generative AI in customer service. A customer complaint that a chatbot invented a refund policy is the triggering event; incident log of hallucinated citations in a legal memo is the evidence for whether the system is high-risk under the EU AI Act.
DECISION Board AI liaison in a retailer using generative AI in customer service must choose Policy or governance breach / Model defect / Dual failure / Hold for the missing fact using incident log of hallucinated citations in a legal memo after a customer complaint that a chatbot invented a refund policy.
HYPOTHESES TO TEST 1. The population in incident log of hallucinated citations in a legal memo is the one a customer complaint that a chatbot invented a refund policy named, so Policy or governance breach follows for this Policy and Oversight file. 2. The population in incident log of hallucinated citations in a legal memo is adjacent only to a customer complaint that a chatbot invented a refund policy; Model defect is the honest AI Governance call. 3. A retailer using generative AI in customer service already contained a customer complaint that a chatbot invented a refund policy before incident log of hallucinated citations in a legal memo arrived; no new Policy and Oversight path. 4. Provenance on incident log of hallucinated citations in a legal memo after a customer complaint that a chatbot invented a refund policy is broken; do not pick Policy or governance breach or Model defect yet.
ANALYSIS REQUIRED 1. Split policy-or-governance failure from a model defect using prompts, outputs, and human edits in incident log of hallucinated citations in a legal memo. 2. Reproduce the incident row in incident log of hallucinated citations in a legal memo and say whether it ever touched production data. 3. Split policy-or-governance failure from a model defect using prompts, outputs, and human edits in incident log of hallucinated citations in a legal memo. 4. For this AI Governance Policy and Oversight file, read incident log of hallucinated citations in a legal memo against a customer complaint that a chatbot invented a refund policy and write the one fact that would move the system is high-risk for board AI liaison.
RECOMMENDATION Choose Policy or governance breach / Model defect / Dual failure / Hold for the missing fact on this AI Governance / Policy and Oversight packet (incident log of hallucinated citations in a legal memo after a customer complaint that a chatbot invented a refund policy). Lead with the AI Governance option incident log of hallucinated citations in a legal memo can support after a customer complaint that a chatbot invented a refund policy, then the two facts that force it, then the Monday action for board AI liaison in a retailer using generative AI in customer service.
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