# Position: EU AI Act's Research Exemptions Can Break the Publication Norms of Major AI Conferences

arXiv: https://arxiv.org/abs/2506.03218 · HTML: https://mlsanity.com/paper/2506.03218/

## Key facts

- No citing papers in the map yet (data through 14 Oct 2026).
- Builds on 14 of its 67 references that are in the map.
- First posted on arXiv 3 Jun 2025.

## Builds on (most cited first, 14 of 14)

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- [Regulating ChatGPT and other Large Generative AI Models](https://mlsanity.com/paper/2302.02337/) (2023)
- [Practical and Ethical Challenges of Large Language Models in Education: A Systematic Scoping Review](https://mlsanity.com/paper/2303.13379/) (2023)
- [Reviving Purpose Limitation and Data Minimisation in Data-Driven Systems](https://mlsanity.com/paper/2101.06203/) (2021)
- [Robustness and Cybersecurity in the EU Artificial Intelligence Act](https://mlsanity.com/paper/2502.16184/) (2025)
- [Moderating Model Marketplaces: Platform Governance Puzzles for AI Intermediaries](https://mlsanity.com/paper/2311.12573/) (2023)
- [The Fundamental Rights Impact Assessment (FRIA) in the AI Act: Roots, legal obligations and key elements for a model template](https://mlsanity.com/paper/2411.15149/) (2024)
- [Forbidden knowledge in machine learning -- Reflections on the limits of research and publication](https://mlsanity.com/paper/1911.08603/) (2019)
- [What constitutes a Deep Fake? The blurry line between legitimate processing and manipulation under the EU AI Act](https://mlsanity.com/paper/2412.09961/) (2024)
- [Non-discrimination law in Europe: a primer for non-lawyers](https://mlsanity.com/paper/2404.08519/) (2024)
- [Critical Infrastructure Protection: Generative AI, Challenges, and Opportunities](https://mlsanity.com/paper/2405.04874/) (2024)

## Abstract (arXiv)

The EU has become one of the vanguards in regulating the digital age. A particularly important regulation in the Artificial Intelligence (AI) domain is the 2024 enacted EU AI Act. The AI Act specifies -- due to a risk-based approach -- various obligations for providers of AI systems. These obligations, for example, include a cascade of documentation and compliance measures, which represent a potential obstacle to science. But do these obligations also apply to AI researchers? This position paper argues that, indeed, the AI Act's obligations could apply in many more cases than the AI community is aware of. Moreover, we argue that the AI Act is drafted in a manner that may unwillingly disrupt the scientific publication practices of the AI research community, with a focus on model and system release. We contribute the following: 1. We offer a high-level roadmap for AI researchers to evaluate whether they need to comply with the AI Act 2. We explain with everyday research examples why the AI Act applies to AI research. 3. We analyse the exceptions of the AI Act's applicability AI research and offer visual tool for researchers to navigate the AI Act's complex system or research exceptions 4. We establish a position the AI Act's research exceptions fail to account for current AI research conventions, as publishing AI research may void the research exceptions of the Act. 5. We propose changes to the AI Act to provide more legal certainty for AI researchers and give two recommendations for AI researchers to reduce the risk of not complying with the AI Act. We see our paper as a starting point for a discussion between policymakers, legal scholars, and AI researchers to avoid unintended side effects of the AI Act.