System
Machine-based autonomous or semi-autonomous system that processes personal data.
How the laws define this
Both frameworks conceptualize a system as a combination of technical elements processing data to enable artificial intelligence functionality or generate outputs. They diverge, however, in their structural criteria and regulatory scope. The Dubai DIFC AI and Emerging Technology Regulatory Sandbox defines a system by its operational behavior—requiring autonomous or semi-autonomous operation—and explicitly limits its scope to systems that process personal data to generate outputs, covering predictive, prescriptive, generative AI, and machine learning. In contrast, the Draft Law (Bill) 'On Artificial Intelligence' — parliamentary bill submitted/considered (Проект Закона «Об искусственном интеллекте») focuses on a physical and structural assembly of software, models, data libraries, hardware, and interfaces active across development, deployment, and operation phases. Furthermore, this parliamentary draft explicitly ties qualifying as a system to statutory obligations, using the definition to determine whether a product or service is subject to registration, testing, and oversight requirements.
Synthesised from the 2 statutory definitions below. Each one is quoted in full, with its source.
Definitions (2)
Any machine-based system operating in an autonomous or semi‑autonomous manner that processes personal data for human‑defined purposes or purposes determined by the system under human‑defined principles and constraints, and that generates output based on such processing. This definition is broad enough to cover predictive, prescriptive, generative AI and machine learning technologies.
An assembly of software, models, data libraries, hardware, and interfaces that together enable AI functionality across development, deployment and operation phases; the statutory scope of obligations (registration, testing, oversight) is determined by whether a product or service qualifies as an AI system under this definition.
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