Adaptive over Static: Why Article 6 Classification Risks Ageing Before It Applies

Response to the European Commission's targeted consultation on the draft Commission guidelines on the classification of high-risk AI systems (Article 6, EU AI Act), and to the Article 112(1) review. The submission argues that fixed, enumerated, intended-purpose-anchored classification ossifies, illustrated by the AI Omnibus deferral of the high-risk obligations to 2027-2028; it submits one design principle - prefer adaptive, criteria-based, self-correcting classification over static enumeration - and recommends treating the Article 112(1) review as a standing adaptive process rather than periodic list-editing.