We use AI carefully, and openly.

Is this legally "an AI system"?

Article 3(1) of the AI Act defines the thing the Act regulates:

"'AI system' means a machine-based system that is designed to operate with varying levels of autonomy and that may exhibit adaptiveness after deployment, and that, for explicit or implicit objectives, infers, from the input it receives, how to generate outputs such as predictions, content, recommendations, or decisions that can influence physical or virtual environments"

The honest answer is that the definition is vague — its criteria have no clear cutoff for a case like ours. Our language-model pipelines clearly infer, but they operate with no autonomy at all: they run in batch, offline, and everything is gated before publication by a human editor. Is a product an "AI system" when its AI components are batch tools behind an editorial desk? The Act's recitals exclude systems that only execute human-defined rules; the Commission's February 2025 guidelines on the definition acknowledge the boundary cases are genuinely hard. Reasonable lawyers disagree; several work here.

Our position: radical transparency. We are not going to litigate the boundary. Out of an abundance of caution, we treat STRIDE as an AI system and comply with Article 50 in full: the labels, the machine-readable marking, the human review, this notice. If the definition is ever read narrowly enough to exclude us, we will simply have over-disclosed.

Grounded discovery: AI-suggested, human-approved

Our discovery pipeline keeps STRIDE current: it watches official registers and regulator publications, and proposes new resources and milestones. The model's job is to find and summarise, never to invent: every proposal carries its source links, retrieval evidence, and the model's own rationale, and a human editor makes the publish decision. The same discipline applies in our internal studio tooling: the model drafts, a person with their name on the audit trail decides.

The pipeline is designed against hallucination: it starts from trusted source registries, crawls and verifies documents before screening, and deduplicates with concrete signals (URL, content hash, title). Reviewers see the whole chain, and are trained on the failure modes, theirs included.

The vocabulary: five categories of provenance, one badge

"AI" is not one thing, and pretending it is would be its own kind of dishonesty: it would let a solved optimisation hide behind the same word as a language model's guess. So we sort every piece of content into one of five categories. The first — generative and unapproved — carries a visible badge, and it has two labels: nothing checked (ai-generated), and machine-checked but with no human sign-off (ai-generated-grounded) — where best-effort automated, non-LLM checks appropriate to the data have run. One more category (ai-assisted) carries a machine-readable provenance field but no badge, because a human approved it. The last three carry no marking at all — but we still name them. That is five categories, the six labels in the table below.

The token is the machine value we attach: it rides in the page as a data-provenance attribute and in our API and MCP responses as a provenance field, so another system, human or AI, can read our claim about a piece of content without guessing.

The cell we are proudest of is ai-generated-grounded. The regulatory and provenance vocabularies in circulation — the AI Act, C2PA, IPTC — are effectively binary: AI-generated, or not. None has a slot for whether the machine checked its own work. Ours does: a cited source confirmed to be real and live, or formal-logic structure gated by determinative checks (type-binding, internal-consistency, span-grounding to the official words, exact solvers) against a hand-made gold standard. That is genuinely different from a raw model guess — it is where we can point you at a check rather than ask you to trust an editor's affirmation. We deliberately keep it to one word rather than grade the checks, because the honest claim is the same whichever ran: a machine looked, a human did not. Two things we will not let it become: the checking does not make it non-AI (the badge still says AI-generated), and grounded does not mean the reading of the law is correct — the checks anchor it to something real, nothing more.

The deeper machinery lives in Lexray

STRIDE is the simple end of our stack, and this notice is short because the product is. The heavier machinery (a provably-optimal alignment solver, neurosymbolic extraction of legal structure, embedding-based semantic search) belongs to our sister product Lexray, which publishes its own, much longer notice with live demonstrations at lexray.simmons-simmons.com/ai-transparency. Where STRIDE links you into legislation text, you are reading Lexray, and that notice applies.

Our commitments

• Content a named editor individually approved publishes as human work; the editor's review is the claim. Anything without that approval carries the "AI-generated" label, uniformly.
• Nothing is generated on demand while you browse STRIDE.
• Editorial responsibility rests with Simmons & Simmons for everything we publish.
• This page is updated in the same change as any new AI feature.