Add a formal serious-incident reporting and response: What is the most direct missing control?
The missing safeguard is a serious-incident process, an additional control for systemic-risk models after other prerequisites are satisfied.
The question
Under the EU AI Act, assume a general-purpose model used in an internal employee-assistance system has systemic risk. Risk evaluation, mitigation, cybersecurity, documentation, and governance are already complete. Testing shows no current harm, but no process addresses serious incidents. What is the most direct missing control?
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- Require conformity assessment before every internal deployment.The EU AI Act distinguishes systemic-risk model duties from high-risk system conformity assessment; repeated assessment is not the stated gap.
- Add a formal serious-incident reporting and response process. ✓Systemic-risk models require serious-incident processes in addition to evaluations, mitigation, cybersecurity, and ordinary technical documentation.
- Publish a general employee notice describing the assistant.A user notice may support transparency, but it does not directly establish the missing systemic-risk serious-incident control.
- Expand routine accuracy testing for employee questions.Accuracy testing is relevant to model quality, but the stated gap concerns systemic-risk incident handling rather than ordinary performance measurement.
The trap
When systemic risk is explicit, look for evaluation, mitigation, serious-incident, and cybersecurity controls separately. How to remember it
The missing safeguard is a serious-incident process, an additional control for systemic-risk models after other prerequisites are satisfied.
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