Is the definition of "AI system" by the OECD too broad?

One thought I had today about the problems of the “AI system” terminology (leaving aside the definition): One effect might be that publishers of machine learning models under non-OSD-conformant licenses would say “well, we have an open model, an open source AI model; we don’t claim that what we have is an “AI system” so we don’t consider it to be subject to the criteria set forth by the OSI in the OSAID”.

In other words, the use of this “system” terminology is a complication that may have the effect of narrowing the perceived scope of what the OSAID covers. Is the thought that the ordinary OSD kicks in in cases where purportedly you don’t have a “system”? That relates to a question that has been raised by at least a few of us here, I think. What is the relationship between the OSD and the OSAID? When does one end and the other begin? I’m concerned the “system” concept creates a loophole of some sort that permits someone to call a model “open” because it is somehow beyond the scope of what the OSD is thought to cover but is also outside of this concept of a “system”.