Photo of Lasse Luecke

Lasse Luecke

Lasse Luecke advises clients on EU regulatory and policy matters with a focus on environmental, technology, and product safety legislation. He has particular expertise in radio equipment legislation, including radiofrequency spectrum use and availability, data center regulation, and sustainability reporting frameworks, where he supports companies in meeting complex and rapidly evolving compliance obligations. Lasse also helps clients anticipate legislative developments, shape regulatory strategy, and engage constructively with EU institutions and policymakers.

There is an ongoing debate in Brussels about the circumstances under which AI-based safety components integrated into radio equipment are subject to the requirements for high-risk AI systems of the EU Artificial Intelligence Act 2024/1689 (the “AI Act”). The debate is particularly relevant because, if AI-based safety components are considered high-risk under the AI Act, they will be subject to a comprehensive set of regulatory requirements under the AI Act as of August 2, 2027. These requirements include risk management, data quality measures, transparency towards users, human oversight, as well as obligations relating to accuracy, robustness, and cybersecurity.

The discussion affects devices like smartphones with AI-driven emergency call features, smart home safety systems, smart home appliances and drones using AI for obstacle avoidance and emergency landing. In effect, many, if not all, of the AI-based safety components of internet-connected radio equipment could be subject to the AI Act’s requirements for high-risk AI systems.

Below we briefly outline the framework of the current debate.Continue Reading When is a Safety Component of Radio Equipment a High-Risk AI System Under the EU Artificial Intelligence Act?