CYMay 23

AI, Digital Platforms, and the New Systemic Risk

arXiv:2509.1787875.23 citationsh-index: 19
Predicted impact top 12% in CY · last 90 daysOriginality Incremental advance
AI Analysis

For regulators and policymakers, the paper provides a more comprehensive framework for systemic risk in AI governance, highlighting gaps in current legislation.

The paper develops a framework for understanding systemic risk in AI, platform, and hybrid systems, drawing from finance and complex systems. It finds that the EU's AI Act and Digital Services Act (DSA) rely on narrow definitions, with the DSA performing better, and identifies four levels of AI-related systemic risk, including risks from multi-agent interactions and collective harms.

As artificial intelligence (AI) becomes increasingly embedded in digital, social, and institutional infrastructures, and AI and platforms are merged into hybrid structures, systemic risk has emerged as a critical but undertheorized challenge. In this paper, we develop a rigorous framework for understanding systemic risk in AI, platform, and hybrid system governance, drawing on insights from finance, complex systems theory, climate change, and cybersecurity - domains where systemic risk has already shaped regulatory responses. We argue that recent legislation, including the EU's AI Act and Digital Services Act (DSA), invokes systemic risk but relies on narrow or ambiguous characterizations of this notion, sometimes reducing this risk to specific capabilities present in frontier AI models, or to harms occurring in economic market settings. The DSA, we show, actually does a better job at identifying systemic risk than the more recent AI Act. Our framework highlights novel risk pathways, including the possibility of systemic failures arising from the interaction of multiple AI agents. We identify four levels of AI-related systemic risk and emphasize that discrimination at scale and systematic hallucinations, despite their capacity to destabilize institutions and fundamental rights, may not fall under current legal definitions, given the AI Act's focus on frontier model capabilities. We then test the DSA, the AI Act, and our own framework on five key examples, and propose reforms that broaden systemic risk assessments, strengthen coordination between regulatory regimes, and explicitly incorporate collective harms.

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