The Many Meanings of Vulnerability in the AI Act and the One Missing

This paper reviews the different meanings of vulnerability in the AI Act (AIA). We show that the AIA follows a rather established tradition of looking at vulnerability as a trait or a state of certain individuals and groups. It also includes a promising account of vulnerability as a relation but does not clarify if and how AI changes this relation. We spot the missing piece of the AIA: the lack of recognition that vulnerability is an inherent feature of all human-AI interactions, varying in degree based on design choices and modes of interaction. Finally, we show how such a meaning of vulnerability may be incorporated into the AIA by interpreting the concept of “specific social situation” in Article 5 (b).