DIS has joined 15 other leading arbitral institutions in submitting comments on the European Commission’s draft Guidelines on high-risk AI systems under the EU AI Act. In their joint submission, the signatories call for the Guidelines to clarify that arbitral institutions, whose role is limited to the administration of proceedings, should not be classified as operators of high-risk AI systems. As arbitral institutions do not adjudicate disputes on the merits, the signatories submit that such a classification should instead apply, where appropriate, to arbitral tribunals using AI in their decision-making functions. The joint submission was made as part of the European Commission’s public consultation on the draft Guidelines, which are expected to be finalised by the end of 2026.