5.1 Conclusion on Whether the Requirements May Apply to ANS
It is currently uncertain whether the requirements for high-risk AI systems in the AIA may apply to ANS deployed in commercial cargo shipping. The uncertainty relates to interpretive issues both within and beyond the AIA. First, although ANS are "AI systems", it is unclear whether they are "high-risk" under Article 6(2). Second, the question of whether the MED is lex specialis to the AIA in the context of ANS remains unresolved.
Current interpretations suggest that ANS may be classified as high-risk AI systems under Article 6(2) when deployed in LNG or LPG shipping.(1) Thesis Section 3.3.4. At the same time, the MED appears to function as lex specialis to the AIA with regard to ANS, but only in relation to components of the systems located on board EU-flagged ships.(2) Thesis Section 3.4. That said, the European Commission may, practically speaking, clarify these issues by February 2026.(3) Thesis Sections 3.3.2 and 3.4.3.