Versatile AI Risk Assessment

AI threat catalogue Harmful Content Production

Unethical Actions

The AI system recommends or produces actions that are legal but ethically questionable, such as manipulation, deception, or exploiting vulnerable users.

As of: October 2026 · Catalogue version 2026.10.24.2 · 5 mitigations · 5 verified sources

Description

Unlike clearly unlawful or criminal content, this concerns practices in an ethical grey area: misleading lines of argument, covert influence, or so-called dark patterns, meaning design choices that push people toward decisions against their own interest. Common content filters rarely catch this, because the behavior does not appear overtly harmful. The AI Act draws the line at deliberately manipulative or deceptive techniques and at exploiting the vulnerability of specific groups of people.

Possible impact

The damage lies mainly in loss of trust and in ethical and reputational consequences for the operator. Where the system's behavior approaches targeted manipulation or the exploitation of vulnerable people, it can move into the range of practices prohibited by the AI Act.

Example

A sales assistant advises pushing undecided customers toward a hasty purchase using artificial scarcity and misleading countdown displays.

Recommended mitigations (5)

Compare effects and implementation levels. Expand each entry for the additional classification and rationale.

  • Ethical guidelines in training

    Governance & compliance
    Effect
    Preventive
    Implementation level
    Model & training, Organization
    Classification and rationale

    Complementary control typeOrganizational & process-based

    Primarily a governance and compliance control: Binding rules, control objectives, or oversight define permitted use and accountability; complemented by binding workflows.

  • Constitutional AI methods

    Technical
    Effect
    Preventive
    Implementation level
    Model & training
    Classification and rationale

    Primarily technical: A model, training, or data-processing method directly changes system behavior or robustness.

  • Ethics review boards

    Governance & compliance
    Effect
    Preventive
    Implementation level
    Organization
    Classification and rationale

    Complementary control typeOrganizational & process-based

    Primarily a governance and compliance control: Binding rules, control objectives, or oversight define permitted use and accountability; complemented by binding workflows.

  • Transparency about model behavior

    Governance & compliance
    Effect
    Preventive
    Implementation level
    Organization, Use & operations
    Classification and rationale

    Complementary control typeOrganizational & process-based

    Primarily a governance and compliance control: Binding rules, control objectives, or oversight define permitted use and accountability; complemented by binding workflows.

  • Refusal patterns for manipulative requests

    Technical
    Effect
    Preventive
    Implementation level
    Model & training, Application, API & agents
    Classification and rationale

    Primarily technical: System-enforced inspection, transformation, or blocking rules stop or neutralize disallowed content before further processing.

Framework mappings

Verified locations in OWASP, NIST AI RMF, MITRE ATLAS, the EU AI Act and further frameworks. The mappings are taxonomic, not evidence of compliance.

NIST AI RMF Section 2.3MITRE ATLAS AML.T0048.002EU AI Act Article 5(1)(a) · Article 55(1)(b) · Article 9(1), 9(2)(a), 9(2)(d)

Verified references (5)

Every reference states the framework, the exact location and the publishing organisation.

EU AI Act obligations related to this threat

The obligations from the obligations compass whose articles the catalogue maps to this threat. Each leads to its entry with core, action step and evidence; whether it applies to you depends on role and risk class.

  • Refrain from the prohibited practices Art. 5 Abs. 1 · applies from 2 February 2025

    Statutory roles: Provider, Deployer, Importer, Distributor, Authorised representative, Product manufacturer, Provider of a general-purpose AI model. Classes: Prohibited practice.

    These prohibitions have applied since 2 February 2025 and are unaffected by the deferral of the high-risk obligations. Infringements carry the highest fine bracket of the regulation.

    This reference is a review prompt. A threat match alone does not establish applicability.

  • New prohibition: intimate depictions without consent Art. 5 Abs. 1 UAbs. 1 Buchst. ba, Art. 5 Abs. 1a, 1b · applies from 2 December 2026 · amended by Reg. 2026/1744

    Statutory roles: Provider, Deployer, Importer, Distributor, Authorised representative, Product manufacturer, Provider of a general-purpose AI model. Classes: Prohibited practice, System subject to transparency obligations.

    This prohibition is new and was inserted by Regulation (EU) 2026/1744. It applies from 2 December 2026. For deployers, the prohibition applies only where the system is used for that very purpose.

    This reference is a review prompt. A threat match alone does not establish applicability.

  • New prohibition: child sexual abuse material Art. 5 Abs. 1 UAbs. 1 Buchst. bb · applies from 2 December 2026 · amended by Reg. 2026/1744

    Statutory roles: Provider, Deployer, Importer, Distributor, Authorised representative, Product manufacturer, Provider of a general-purpose AI model. Classes: Prohibited practice.

    Also newly inserted by Regulation (EU) 2026/1744, applying from 2 December 2026.

    This reference is a review prompt. A threat match alone does not establish applicability.

  • Establish and operate a risk management system Art. 9 · applies from Annex III: 2 December 2027 · Annex I: 2 August 2028

    Statutory roles: Provider, Product manufacturer. Classes: High-risk under Annex III, High-risk as a product or safety component.

    This reference is a review prompt. A threat match alone does not establish applicability.

  • Evaluate and mitigate systemic risks Art. 55 · applies from 2 August 2025

    Statutory roles: Provider of a general-purpose AI model. Classes: Model with systemic risk.

    This reference is a review prompt. A threat match alone does not establish applicability.

All 62 obligations by role, risk class and deadline in the obligations compass

More entries from the topic group Harmful Content.

Hate Speech and Discrimination The AI system produces content that demeans individuals or groups on the basis of protected characteristics such as origin, gender, … Profanity The AI system produces vulgar or offensive language in a setting where this is unprofessional or against policy, such as customer support, … Sexual Content The AI system produces sexually explicit or suggestive content in a context where it is inappropriate, unwanted, or unlawful.

Matching use cases

This list shows where to review this threat, rather than how high the risk is.

Typical for:

For 6 further use cases, relevance depends on the system design, for example whether it generates new content from open-ended requests or generates its own text. Show these use cases

Frequently asked questions

What is Unethical Actions?
The AI system recommends or produces actions that are legal but ethically questionable, such as manipulation, deception, or exploiting vulnerable users.
Which mitigations help against Unethical Actions?
The catalogue lists 5 mitigations, each with control type, effect and implementation level. First among them are Ethical guidelines in training, Constitutional AI methods and Ethics review boards.
Which EU AI Act obligations does Unethical Actions touch?
The catalogue maps this threat to Art. 5 Abs. 1, Art. 5 Abs. 1 UAbs. 1 Buchst. ba, Art. 5 Abs. 1 UAbs. 1 Buchst. bb, Art. 9 and Art. 55 of the EU AI Act. In the obligations compass this leads to: Refrain from the prohibited practices, New prohibition: intimate depictions without consent, New prohibition: child sexual abuse material, Establish and operate a risk management system and Evaluate and mitigate systemic risks. Whether an obligation applies depends on role, risk class and deadline.

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Cite this entry

For reports, policies or internal documents; the link leads directly to this entry.

“Unethical Actions”. Versatile AI Risk Assessment, AI threat catalogue, as of October 2026.
https://www.versatile-ai-risk-assessment.com/en/wissensbasis/threats/unethical-actions/

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