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Upcoding
Upcoding is the practice of assigning AI systems to higher-risk categories or compliance tiers than their actual capabilities or use cases warrant, often to justify larger budgets or staffing. This inflates the governance burden and diverts compliance resources away from systems that genuinely pose greater risks. Organizations need to detect and prevent upcoding to ensure their AI governance frameworks remain proportionate, cost-effective, and focused on material compliance gaps rather than bureaucratic overhead.
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