EU AI Act gaps and proportionate safeguards for research agents
Göktuğ Serdar Yıldırım, Aytekin İsmail, Zahra Safdari Fesaghandis , Şevval Sude Çeliker
AI research agents can affect real people through authorized network access even when their host sandbox remains intact. UK AI Security Institute tests the capabilities of frontier AI models before it reaches public. On the 28th of July, some of the AI agents being tested engaged in sustained, potentially harmful activity directed at real people and organizations. This raises a question: could the EU consistently govern an equivalent evaluation in the Union? We studied this by comparing the public facts of the incident against the EU AI Act's scope, who's responsible for what, and when incidents must be reported, alongside the related General Purpose AI Safety and Security Code and other regulations. The analysis identifies eight concerns: ambiguous research boundaries, incomplete coverage of dangerous agents, divided operational responsibility, reporting of serious near misses, action containment, shared resources between agents, evidence preservation, and attributable identities. The strongest findings concern gaps in coverage, responsibility, and reporting, while the remaining findings specify how to implement and test existing protections. To address these gaps, we propose basing compliance requirements on two factors: how capable an AI agent is and how much real-world exposure it has, with stricter rules kicking in as both increase, and shifting oversight toward whoever controls the agent at runtime rather than just its original developer. Furthermore, we draw a limited analogy to carbon-border compliance to illustrate how supply-chain accountability might condition market access on verifiable risk containment.
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@misc {
title={
(HckPrj) EU AI Act gaps and proportionate safeguards for research agents
},
author={
Göktuğ Serdar Yıldırım, Aytekin İsmail, Zahra Safdari Fesaghandis , Şevval Sude Çeliker
},
date={
},
organization={Apart Research},
note={Research submission to the research sprint hosted by Apart.},
howpublished={https://apartresearch.com}
}


