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arXiv · 2604.04604

AI Agents Under EU Law

Luca Nannini·Adam Leon Smith·Michele Joshua Maggini·Enrico Panai·Sandra Feliciano·Aleksandr Tiulkanov·Elena Maran·James Gealy·Piercosma Bisconti
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Abstract

AI agents - i.e. AI systems that autonomously plan, invoke external tools, and execute multi-step action chains with reduced human involvement - are being deployed at scale across enterprise functions ranging from customer service and recruitment to clinical decision support and critical infrastructure management. The EU AI Act (Regulation 2024/1689) regulates these systems through a risk-based framework, but it does not operate in isolation: providers face simultaneous obligations under the GDPR, the Cyber Resilience Act, the Digital Services Act, the Data Act, the Data Governance Act, sector-specific legislation, the NIS2 Directive, and the revised Product Liability Directive. This paper provides the first systematic regulatory mapping for AI agent providers integrating (a) draft harmonised standards under Standardisation Request M/613 to CEN/CENELEC JTC 21 as of January 2026, (b) the GPAI Code of Practice published in July 2025, (c) the CRA harmonised standards programme under Mandate M/606 accepted in April 2025, and (d) the Digital Omnibus proposals of November 2025. We present a practical taxonomy of nine agent deployment categories mapping concrete actions to regulatory triggers, identify agent-specific compliance challenges in cybersecurity, human oversight, transparency across multi-party action chains, and runtime behavioral drift. We propose a twelve-step compliance architecture and a regulatory trigger mapping connecting agent actions to applicable legislation. We conclude that high-risk agentic systems with untraceable behavioral drift cannot currently satisfy the AI Act's essential requirements, and that the provider's foundational compliance task is an exhaustive inventory of the agent's external actions, data flows, connected systems, and affected persons.

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Luca Nannini, Adam Leon Smith, Michele Joshua Maggini, Enrico Panai, Sandra Feliciano, Aleksandr Tiulkanov, Elena Maran, James Gealy, Piercosma Bisconti. 2026-04-06. AI Agents Under EU Law. https://arxiv.org/abs/2604.04604

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