欧盟AI法案研究豁免或破坏科研发布惯例，需警惕合规风险

The EU has become one of the vanguards in regulating the digital age. A particularly important regulation in the Artificial Intelligence (AI) domain is the 2024 enacted EU AI Act. The AI Act specifies -- due to a risk-based approach -- various obligations for providers of AI systems. These obligations, for example, include a cascade of documentation and compliance measures, which represent a potential obstacle to science. But do these obligations also apply to AI researchers? This position paper argues that, indeed, the AI Act's obligations could apply in many more cases than the AI community is aware of. Moreover, we argue that the AI Act is drafted in a manner that may unwillingly disrupt the scientific publication practices of the AI research community, with a focus on model and system release. We contribute the following: 1. We offer a high-level roadmap for AI researchers to evaluate whether they need to comply with the AI Act 2. We explain with everyday research examples why the AI Act applies to AI research. 3. We analyse the exceptions of the AI Act's applicability AI research and offer visual tool for researchers to navigate the AI Act's complex system or research exceptions 4. We establish a position the AI Act's research exceptions fail to account for current AI research conventions, as publishing AI research may void the research exceptions of the Act. 5. We propose changes to the AI Act to provide more legal certainty for AI researchers and give two recommendations for AI researchers to reduce the risk of not complying with the AI Act. We see our paper as a starting point for a discussion between policymakers, legal scholars, and AI researchers to avoid unintended side effects of the AI Act.