The AI Act and its green blind spots: Hidden environmental risks in the AI lifecycle

The European Union Artificial Intelligence (AI) Act is the first comprehensive regulatory framework for AI, establishing a risk-based approach. It addressed environmental sustainability only to a limited extent. Environmental impacts are not considered a separate category of risks but are tackled indirectly through procedural mechanisms, including transparency, documentation, and governance requirements. Many have questioned whether this approach adequately covers environmental concerns. Yet, few examined how such claims manifest through its compliance mechanisms. The article addresses this gap through a doctrinal and operational analysis of the Act, identifying and coding the environment-relevant provisions across its Articles and Annexes. Particular attention is paid to implementation via conformity assessment and post-market governance processes. The analysis highlights a tension between the Union’s constitutional commitment to environmental protection and the often modest, non-mandatory environment-related obligations under the Act, scattered across procedural duties. Based on these findings, an operational reform pathway is suggested that relies on shared standards integrating life-cycle assessment and post-market monitoring, without altering the Act’s risk classification. • Analyzes how the AI Act engages with environmental sustainability. • Reveals limits in the Act’s approach to lifecycle environmental risks. • Proposes a Lifecycle Governance Model for integrating sustainability into AI law. • Links environmental integration, risk regulation, and responsible innovation theory. • Outlines policy pathways for integrating sustainability in digital regulation.