European Commission final study report

Report for the European Commission on Article 5(1)(a) and (b) of the AI Act

A comprehensive analysis of subliminal, purposefully manipulative, deceptive and vulnerability-exploitative AI practices, including constitutive elements, enforcement challenges, use cases and interaction with the wider EU digital acquis.

Cover of Report for the European Commission on Article 5(1)(a) and (b) of the AI Act
2026Publications Office of the European Union

What the report examines

A comprehensive analysis of subliminal, purposefully manipulative, deceptive and vulnerability-exploitative AI practices, including constitutive elements, enforcement challenges, use cases and interaction with the wider EU digital acquis.

  • Legal analysis of the constituent elements and legislative intent of Article 5(1)(a) and (b).
  • Stakeholder perspectives, practical use cases, exceptions and enforcement considerations.
  • Cross-regulatory analysis spanning the AI Act, GDPR, DSA, DMA, Data Act, consumer law and non-discrimination law.

Publication identifier: KK-01-25-094-EN-N
ISBN: 978-92-68-29176-4
DOI: 10.2759/0691115

DigiData approach

From legal boundary to operational consequence.

The report sits within DigiData’s wider practice of connecting legal interpretation with use cases, institutional incentives, evidence and implementable choices. The downloadable PDF remains the authoritative publication; this page provides a concise, indexable summary and clear route to the source.

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