A system that has drifted from its intended purpose into a higher-risk domain since classification requires reclassification before any further risk assessment proceeds. Reclassification triggers include a material change in the system’s intended purpose or deployment context, expansion to a new sector or jurisdiction that alters the system’s risk profile, post-market monitoring data revealing risks not anticipated in the original classification, competent authority guidance or enforcement action affecting the classification of comparable systems, and amendments to the AI Act’s Annexes that change which systems qualify as high-risk.

The risk assessment cycle includes a classification confirmation step at every quarterly review, verifying that no reclassification triggers have been activated. The PMM feedback loop specifically monitors for deployment context changes that could affect classification.

Where a reclassification trigger is identified, the AI System Assessor conducts a fresh classification analysis, produces a revised CDR, and submits it for independent review. If the reclassification moves the system to a higher tier, the AISDP must be extended to meet the higher tier’s requirements before the system continues operating.

Key outputs

• Defined reclassification triggers (purpose drift, sector expansion, PMM findings, regulatory change)
• Classification confirmation at every quarterly review
• Fresh CDR analysis and independent review on trigger activation
• Module 6 and Module 12 AISDP documentation