On 23 July 2026, PensionsEurope published its answer to the EC’s consultation on draft guidelines on the classification of high-risk AI systems. In our answer, we indicated that the extension to personal pension products in paragraph 317 goes beyond the level 1 legislation. Pension products are not mentioned in Point 5(c) of Annex III to the AI Act and should not be introduced into its scope by means of interpretative guidance. Extending the level 1 requirements through guidelines creates legal uncertainty for providers and deployers operating in the pensions sector.
On 23 July 2026, PensionsEurope published its answer to the EC’s consultation on draft guidelines on the classification of high-risk AI systems. In our answer, we indicated that the extension to personal pension products in paragraph 317 goes beyond the level 1 legislation. Pension products are not mentioned in Point 5(c) of Annex III to the AI Act and should not be introduced into its scope by means of interpretative guidance. Extending the level 1 requirements through guidelines creates legal uncertainty for providers and deployers operating in the pensions sector.
