Vulnerability in the EU AI Act: building an interpretation

Abstract

The EU Artificial Intelligence Act (AIA) integrates the concept of (human) vulnerability as a critical element for categorising high-risk AI systems, prohibiting exploitative practices, and enforcing safeguards for fundamental rights. Yet the Act lacks a unified definition, leading to fragmented and inconsistent application. This paper addresses this gap by proposing a comprehensive framework for understanding vulnerability in the AIA, rooted in interdisciplinary scholarship and EU legal traditions. We argue that vulnerability should be understood as a heightened risk to fundamental rights arising from power imbalances, dependencies, and varying levels of personal or structural resilience. Through a systematic analysis of the AIA's vulnerability-related provisions, we demonstrate how this framework can harmonise its diverse references, inform risk assessments, and guide regulatory enforcement.

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