Assess whether the system is high-risk under the EU AI Act (914c64)
August 31, 2026
SITUATION Board AI liaison in a bank preparing for a model-risk exam has one working extract — training-data provenance questionnaire — after a new use case bolted onto a model approved for a narrower purpose. If training-data provenance questionnaire cannot support the system is high-risk, the only defensible AI Governance output is hold.
DECISION Board AI liaison in a bank preparing for a model-risk exam must choose Policy or governance breach / Model defect / Dual failure / Hold for the missing fact using training-data provenance questionnaire after a new use case bolted onto a model approved for a narrower purpose.
HYPOTHESES TO TEST 1. Training-data provenance questionnaire reads as Policy or governance breach once a new use case bolted onto a model approved for a narrower purpose is lined up to the same AI Governance population. 2. Training-data provenance questionnaire is closer to Model defect after a new use case bolted onto a model approved for a narrower purpose; Policy or governance breach would over-claim this Vendors and Agentic Systems extract. 3. Dual failure is still live in training-data provenance questionnaire for board AI liaison in a bank preparing for a model-risk exam. 4. Training-data provenance questionnaire is missing the fact board AI liaison needs after a new use case bolted onto a model approved for a narrower purpose; stop this AI Governance close.
ANALYSIS REQUIRED 1. Reproduce the incident row in training-data provenance questionnaire and say whether it ever touched production data. 2. Split policy-or-governance failure from a model defect using prompts, outputs, and human edits in training-data provenance questionnaire. 3. Reproduce the incident row in training-data provenance questionnaire and say whether it ever touched production data. 4. For this AI Governance Vendors and Agentic Systems file, read training-data provenance questionnaire against a new use case bolted onto a model approved for a narrower purpose 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 / Vendors and Agentic Systems packet (training-data provenance questionnaire after a new use case bolted onto a model approved for a narrower purpose). If training-data provenance questionnaire cannot force a AI Governance label under Vendors and Agentic Systems, stop. If training-data provenance questionnaire after a new use case bolted onto a model approved for a narrower purpose cannot support Policy or governance breach versus Model defect on this AI Governance Vendors and Agentic Systems close, board AI liaison must leave the classification unresolved and name the missing control or provenance fact.
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