Defining High‐Impact AI in Autonomous Shipping: Legal Frameworks, Supply Chain Resilience, and Maritime Safety Dimensions
TL;DR
This paper proposes five interrelated criteria for classifying autonomous shipping AI as high‐impact—functional centrality to navigation and safety, reliability under maritime stress, systemic harm potential upon malfunction, dependence on real‐time data integrity, and structural absence of human override.
Abstract
The rapid emergence of Maritime Autonomous Surface Ships (MASS) has made the governance of artificial intelligence systems a question of immediate regulatory urgency. The European Union's Artificial Intelligence Act (2024) and the Republic of Korea's AI Framework Act (2025) are the first two horizontal, binding, risk‐tiered AI statutes in force, yet neither provides operationally adequate criteria for classifying AI systems aboard autonomous vessels. Maritime transport sits outside the EU Act's Annex III, and Korea's Act defers the operative classification to guidelines whose maritime treatment remains incomplete. This paper proposes five interrelated criteria for classifying autonomous shipping AI as high‐impact—functional centrality to navigation and safety, reliability under maritime stress, systemic harm potential upon malfunction, dependence on real‐time data integrity, and structural absence of human override—grounded in the operational realities of autonomous vessels and the legal obligations both frameworks activate once the threshold is crossed. Because roughly four‐fifths of world trade by volume moves by sea through a small number of congested chokepoints, accurate classification is also a question of supply chain resilience, with dimensions extending beyond technical risk to seafarer welfare, marine‐environmental integrity, and the democratic legitimacy of a transition whose pace has outrun the governance architecture intended to steer it.