Legal AI in Higher Education: Building Compliance & Innovation Together

Recently, in the Brussels office of the University of Helsinki, we convened with partners from across seven Ulysseus Alliance universities (France, Finland, Spain, Austria, Germany, Slovenia, and Italy) to co-create a legal framework grounded in the EU AI Act. This framework will guide all AI-supported joint programs, technical solutions, and digital credentials across the alliance.

Core Aspects of the EU AI Act We Addressed:

1. Embedded "High-Risk" Classification in EducationUnder the EU AI Act, AI systems used for admissions, evaluation, learning assessment, or student monitoring are designated as high-risk, introducing a suite of compliance obligations (risk management, governance, technical documentation, transparency, human oversight, cybersecurity).

2. Prohibition of Emotion Recognition AI in Educational SettingsThe Act explicitly bans emotion inference technologies, such as facial expression or sentiment analysis, in learning environments, due to concerns about fairness, bias, and privacy.

3. Mandatory AI LiteracyArticle 4 requires all providers and deployers of AI systems to ensure sufficient training and literacy for staff and users - an essential element to ensure ethical and compliant adoption.

4. Transparency for AI-Generated ContentUnder the Act, all AI-generated content (e.g., from ChatGPT or similar tools) must be clearly labeled to prevent misinformation and safeguard rights—reinforcing trust and accountability.

What We're Embedding in the Framework:

• Mandatory AI & Legal Compliance Training for all students, faculty, and staff.

• Guidance on High-Risk AI: Clear protocols for admissions, grading, monitoring tools, with technical safeguards, oversight, and documentation baked in.

• Ban on Emotion Recognition: Explicit prohibition in all teaching and assessment processes.

• Transparency Standards: AI-generated materials must be labeled; content provenance clearly indicated.

• Human Oversight Requirements: Every AI-supported decision must include human review and traceability.

• Ethics & Privacy At the Core: Risk assessments, documentation, and governance processes embedded throughout.

This framework, now in its finalizing stage, builds on my dual expertise, as an instructional designer, an AI and data protection specialist trained at NOVA Law School Lisbon, and a digital credentials expert capable of balancing pedagogical needs with legal mandates. I have coordinated this across our alliance, aligning leaders, technical teams, and academic stakeholders with enterprise-level expectations and regulatory clarity.

Why This Matters for Enterprises:

• Compliant Co-Creation: Companies collaborating with universities on AI tools or curricula can rely on a legally sound, EU-aligned foundation.

• Trusted AI Use: Framework enables safe, transparent AI adoption, minimizing reputational and legal risks.

• Learning & Talent Development: AI-supported programs will produce graduates who are not just technically capable, but also legally and ethically literate.

• Governance-Ready Partnerships: Enterprises can engage knowing that institutional use of AI meets high standards, spurring innovation in certifications, micro-credentials, and joint offerings.