Which AI use cases in telecommunications are high risk under the EU AI Act?

Scoring individual agents' interactions to monitor and evaluate their performance and behavior falls under Annex III point 4(b), employment and worker management. The Article 6(3) exception does not apply where the system profiles natural persons. Inferring agents' emotions is prohibited under Article 5(1)(f), except for medical or safety reasons. Inferring customers' emotions from their voice is emotion recognition on biometric data: high risk under Annex III point 1(c), and Article 50(3) requires informing the people exposed to it. Analytics that only aggregate interaction themes without evaluating individuals can fall outside the high risk category.

A sales assistant is limited risk with an Article 50 duty to disclose AI. If it assesses the creditworthiness of individuals for devices on credit, that part is high risk under Annex III point 5(b), so keep credit decisions in the existing governed process. Selling that uses manipulative or deceptive techniques, or exploits a customer's age, disability or economic situation, to materially distort a purchase decision in a way likely to cause significant harm is prohibited under Article 5(1)(a) and (b).

Annex III point 2 lists AI systems intended as safety components in the management and operation of critical digital infrastructure as high risk; Recital 55 ties this to the digital infrastructure in the Annex to Directive (EU) 2022/2557, which includes providers of public electronic communications networks. Recital 55 defines such safety components as systems that directly protect the physical integrity of the infrastructure or the health and safety of persons and property, and excludes components used solely for cybersecurity. Loops that only optimize performance or capacity are usually not safety components, but a loop that protects physical integrity or life safety services can be, so operators should assess each closed loop and document the outcome.

The main test is Annex III point 2, which lists AI systems intended as safety components in the management and operation of critical digital infrastructure as high risk. A copilot that prepares diagnoses for engineers who decide every change is normally not such a safety component, and is then minimal risk. The tier rises when the system is designed to protect the safe operation of the network, for example by acting on it automatically to prevent or contain outages. Article 6(3) can exempt an Annex III system that only performs a preparatory task to an assessment and poses no significant risk of harm, provided the provider documents that assessment and registers the system.

Forecasting demand, ranking congested cells and recommending investments is normally minimal risk. Under Article 6(2), Annex III point 2 lists AI systems intended as safety components in the management and operation of critical digital infrastructure as high risk, and Recital 55 ties this to the digital infrastructure in the Annex to Directive (EU) 2022/2557, which includes providers of public electronic communications networks. Recital 55 defines such safety components as systems that directly protect the physical integrity of the infrastructure or the health and safety of persons and property and that are not necessary for the system to function. Closed loop parameter optimization on the live radio network is high risk only when it serves in that role, for example a loop whose purpose is to protect emergency call availability, so each automated loop should be assessed against point 2 and the outcome documented. Loops that only optimize performance or capacity are usually not safety components.

Scoring failure risk and planning maintenance is normally minimal risk. Annex III point 2 lists AI systems intended as safety components in the management and operation of critical digital infrastructure as high risk, and public electronic communications networks fall within that infrastructure. Recital 55 limits safety components to systems that directly protect the physical integrity of the infrastructure or the health and safety of persons and property, and excludes components used solely for cybersecurity. An operator whose automated actions meet that test must treat the system as high risk.

Optimizing energy use is normally minimal risk. Under Article 6(2), Annex III point 2 lists AI systems intended as safety components in the management and operation of critical digital infrastructure as high risk, and public electronic communications networks fall under that infrastructure. Recital 55 limits safety components to systems that directly protect the infrastructure or the health and safety of persons, so an optimizer is not high risk by default, but a design in which it could affect emergency service availability should be assessed against point 2.

Triage and a knowledge copilot for technicians are normally minimal risk. Annex III point 4(b) lists AI systems that allocate tasks based on individual behavior or personal traits, or that monitor and evaluate the performance and behavior of workers, as high risk, so dispatch systems that do this need the full high risk controls, and under Article 26(7) employers must inform workers' representatives and the affected workers before using them. A conversational assistant that answers customers directly carries the Article 50 duty to tell people they are dealing with AI.

Churn scoring and offer selection for marketing are not listed in Annex III, so a back office design that only scores customers and prompts human advisors is minimal risk, with no specific obligations. When an AI agent delivers the offer to the customer in chat, messaging or voice, the system is limited risk: Article 50 requires telling customers they are dealing with AI. A design that used manipulative techniques or exploited vulnerabilities to keep customers from leaving could fall under the Article 5 prohibitions. GDPR rules on profiling and the right to object to direct marketing (Article 21) apply in full.

Checking photos of network equipment is normally minimal risk. If the output is used to allocate tasks based on individual behavior or personal traits, or to monitor or evaluate individual technicians or contractor workers, Annex III point 4(b) treats the system as high risk, and under Article 26(7) employers must inform workers' representatives and the affected workers before using it. Keep the model on the work, not the person.

The customer facing agent is limited risk with an Article 50 duty to disclose AI. AI used as a safety component in the management and operation of critical digital infrastructure is high risk under Annex III point 2, so the classification depends on whether the detection part acts on the network or only informs people.

Fraud detection is not listed as high risk in Annex III, and point 5(b) explicitly excludes systems used to detect financial fraud from the creditworthiness category. Blocking fraud traffic is not normally a safety component of critical digital infrastructure (point 2). The tier can change if the same scores are reused for an Annex III purpose: eligibility for essential public assistance benefits and services (point 5(a)), creditworthiness or credit scoring of natural persons (point 5(b)), or risk assessment and pricing for life and health insurance (point 5(c)). A voice or chat agent that takes fraud reports from customers also carries the Article 50(1) duty to tell people they are dealing with an AI system.

Summaries, CRM suggestions and follow up drafts that the seller reviews are not an Annex III use and are minimal risk. Using call analysis to monitor and evaluate the performance and behavior of individual sellers, or to allocate leads to sellers based on their behavior or personal traits, is high risk under Annex III point 4(b). Inferring sellers' emotions from their voice is prohibited in the workplace by Article 5(1)(f). Emotion recognition applied to customers' voices is high risk under Annex III point 1(c), and Article 50(3) requires deployers to inform the people exposed to it.

As a pure assist tool for agents it is minimal risk; the customer does not interact with the AI. It becomes high risk under Annex III point 4(b) if its data is used to monitor and evaluate individual agents' performance, and inferring agents' emotions at work is prohibited under Article 5(1)(f).

Annex III point 5(b) excludes AI used to detect financial fraud from the high risk credit scoring category, but a system that in effect decides on creditworthiness is high risk, and remote biometric identification is high risk under point 1(a), which excludes one to one biometric verification. When a public authority uses the model on claims for public benefits, point 5(a) can apply, because it covers AI used to grant, reduce, revoke or reclaim benefits and has no fraud exception. Keep fraud detection separate from the credit or eligibility decision and use biometrics only for one to one verification.

Complaint handling is not listed in Annex III, so internal classification and drafting for a handler who decides is minimal risk. Where the agent talks to customers to take the complaint, Article 50(1) requires telling them they are dealing with AI. Only a system that also assessed creditworthiness or priced life and health insurance (Annex III point 5(b) or 5(c)) would be high risk for that part.

Used only for practice and feedback, the simulator is limited risk. Article 50 requires that people know they are interacting with AI unless that is obvious from the context, as it usually is in a training session, and the provider must mark synthetic voice or text output as AI generated in a machine readable format. It becomes high risk under Annex III point 4(b) if its scores are used to evaluate the performance of workers or to decide on their promotion or termination, and can fall under point 3(b) when a vocational training institution uses it to evaluate learning outcomes. Inferring trainees' emotions from voice or face in the workplace is prohibited under Article 5(1)(f), except for medical or safety reasons.

An AI system that interacts directly with people must be designed so that they know they are dealing with AI, unless that is obvious from the context (Article 50(1)). It is not high risk under Annex III as long as it does not evaluate eligibility for essential public assistance benefits and services (point 5(a)), creditworthiness (point 5(b)), risk and pricing for life and health insurance (point 5(c)) or emergency calls (point 5(d)). This holds only if emotion or vulnerability signals are inferred from what the customer says (text or transcript content), not from voice or other biometric features; an agent that infers emotion from a caller's voice is an emotion recognition system (Article 3(39)), which is high risk under Annex III point 1(c) and triggers the deployer disclosure duty in Article 50(3).

A digital human or kiosk that talks to customers must be designed so that they are told they are interacting with an AI system (Article 50(1)). An associate copilot over product content is not listed in Annex III and is minimal risk. Inferring the emotions of employees at work is prohibited (Article 5(1)(f)); emotion recognition of customers by camera is high risk under Annex III point 1(c), biometric categorization by sensitive or protected attributes is high risk under Annex III point 1(b), and categorization that infers race, political opinions, religion or sexual orientation is prohibited under Article 5(1)(g). Both need separate legal review.

Article 50(1): people must be informed that they are interacting with an AI system, unless that is obvious from the context. Quoting, sales support and service for business customers are not listed in Annex III. The use would become high risk under Annex III point 5(b) only if the assistant itself evaluated the creditworthiness of a natural person, such as a sole trader, to decide whether to offer a contract.

A customer facing troubleshooting agent must tell people they are interacting with AI unless that is obvious (Article 50). It is not high risk as long as it is not used as a safety component in the management and operation of critical digital infrastructure (Annex III, point 2); running line tests and resets for one customer's service does not make it one.

A customer facing assistant must be designed so that people know they are interacting with AI (Article 50(1)). Explaining bills, correcting clear errors and opening disputes are not listed in Annex III. The tier changes only if the system is also used to evaluate customers' creditworthiness, for example to set credit limits, which Annex III point 5(b) lists as high risk.

A customer facing assistant must disclose that it is AI (Article 50). Biometric verification whose sole purpose is to confirm that a person is who they claim to be is excluded from remote biometric identification in Annex III point 1(a); creditworthiness assessment of individuals (Annex III point 5(b)) would be high risk and belongs in a separate governed process.

A treasury assistant interacts directly with staff, so Article 50(1) requires that they are informed they are dealing with an AI system unless that is obvious from the context. It is not listed in Annex III and makes no decision about a natural person.

A drafting copilot whose output an agent reviews and sends falls under the transparency tier at most. When replies are sent without human review, customers interact with the AI system directly, and Article 50(1) requires that they are informed unless this is obvious from the context. Article 50(2) separately requires the provider of a system that generates text to mark its output in a machine readable format as artificially generated, whether or not a person reviews the draft. It becomes high risk only if it is used for a purpose listed in Annex III, such as evaluating eligibility for public benefits or creditworthiness (point 5), or evaluating the performance of the agents who use it (point 4).

A customer facing collections agent must disclose that it is AI (Article 50). It is not listed in Annex III as long as it applies preapproved arrangement rules and does not itself evaluate creditworthiness; an affordability model that decides who gets which arrangement for individuals should be assessed separately against Annex III point 5(b).

Designing and costing a proposed fibre route is planning for new construction, not the management or operation of an existing network, and it does not decide anything about an individual person. It is not a use listed in Annex III. Annex III point 2 (safety components in the management and operation of critical digital infrastructure) targets systems that are safety components in running live infrastructure; a route and cost planning assistant for new construction is not part of managing or operating that infrastructure, so it does not fall under it. Because it plans investment in a public electronic communications network, general obligations for network operators under the NIS2 Directive still apply to the operator, separately from the AI Act.

Scoring, blocking and labeling calls is not listed in Annex III, is not a prohibited practice under Article 5, and the system does not interact with people or generate content, so Article 50 does not apply. A conversational scambaiting agent such as O2's Daisy talks to callers with a synthetic voice, which raises separate Article 50 transparency questions and should be assessed on its own.

Tuning radio channels and traffic priorities in a home network is not listed in Annex III. Point 2 covers safety components in critical digital infrastructure, and the in home LAN and gateway are not the public electronic communications network. Recital 55 limits safety components to systems that protect the physical integrity of that infrastructure, which channel tuning does not do. The system also does not interact with the customer as a conversational system. A chatbot or voice assistant that explains the changes to customers carries the Article 50 duty to say it is AI, unless that is obvious.

Analyzing complaints in aggregate to find causes is not listed in Annex III, is not a practice prohibited by Article 5 and does not decide on individuals. It does not interact with the public, so the disclosure duty in Article 50(1) does not apply; the machine readable marking of generated text in Article 50(2) is a duty of the provider of the generative model or system that writes the summaries. If the same system decided individual complaint outcomes or redress, or its themes were used to evaluate the performance of individual complaint handlers (Annex III point 4), that design would need its own assessment.

An internal tool that supports engineers on IT incidents; it is not a use listed in Annex III and makes no decisions about people. Annex III point 2 covers AI used as a safety component in the management and operation of critical digital infrastructure, and recital 55 limits safety components to systems that directly protect the physical integrity of that infrastructure or the health and safety of persons and property. A triage copilot that proposes causes and fixes to engineers does not normally do that, but operators of critical digital infrastructure (cloud, data centers, telecom networks) should confirm this for their own design.