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L2-M2 / lesson 2 of 2

Recognise when changes create new responsibilities

The consultancy adds a new decision-making feature.

10–15 min · 0/4 steps complete

Start here / A workplace decision

A change can alter responsibilities

The consultancy adds a new decision-making feature.

The team describes the update as only fine-tuning.

Before you read / Think it through

In “A change can alter responsibilities”, what would you check or do first?

Pause and form your answer, then compare the reasoning. This reflection is not scored.

Compare the reasoning

Assess what changed in purpose, performance and compliance-relevant behaviour.

The ideas below give you a method for this decision. Then work through the rest of this case and try the decisions yourself.

Part 1 of 4 Learn the ideas
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Substantial modifications

A substantial modification is a defined legal concept.

Changes affecting compliance or intended purpose need assessment.

In the workplace

Do not equate every parameter change with provider status. Compare the change with the original conformity assessment and intended purpose.

Remember this

Routine updates are not automatically substantial.

The workplace case
YOUR CASE / PROVIDER OR DEPLOYER

A consultancy buys a language-model API and builds its own branded recruitment-screening application for clients. It also uses an unchanged third-party meeting assistant internally. The API supplier says it accepts no responsibility for the consultancy's hiring workflow.

Quick reference / five key ideas
Substantial modifications
Routine updates are not automatically substantial.
New high-risk purposes
Review the purpose before release, not after an incident.
Fine-tuning and integration
Record compute, capability and purpose changes where relevant.
AI Act and GDPR roles
Contract labels must match actual conduct.
Evidence and cooperation
Test whether evidence can actually be obtained.