Governing What the EU AI Act Excludes: Accountability for Autonomous AI Agents in Smart City Critical Infrastructure

Summary

This research paper identifies an accountability deficit for autonomous AI agents operating in smart city critical infrastructure under the EU AI Act, noting that specific provisions exclude safety-component AI from certain explanation rights and impact assessments. It proposes AgentGov-SC, a three-layer governance architecture specifying 25 measures, 5 conflict resolution rules, and an autonomy-calibrated activation model, with bidirectional traceability to established AI frameworks. A scenario analysis traces the governance activation through a multi-agent corridor cascade involving documented UAE smart-city systems. Why it matters: This paper addresses a significant regulatory gap in AI governance for complex, multi-agent systems in critical urban infrastructure, offering a novel architectural solution highly relevant to global smart city initiatives, including those in the Middle East.