Document risk management: Which missing control is most direct? | AIGP
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Document risk management: Which missing control is most direct?

AIGP Understanding How Laws, Standards and Frameworks Apply to AI Hard

The absent evidence is a documented lifecycle risk-management process, not additional disclosure, training summaries, or monitoring alone.

The question

Under the EU AI Act, assume all relevant duties apply. A high-risk travel-support system recommends eligibility for a regulated travel authorization. Provider and deployer roles, data governance, technical documentation, transparency, human oversight, accuracy, robustness, and cybersecurity are satisfied. The file contains test results but no documented process for identifying, evaluating, and mitigating foreseeable risks across the system lifecycle. Which missing control is most direct?

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  1. Extend post-market monitoring
    Monitoring after deployment is valuable, but the stated deficiency is the missing documented process spanning risk identification and mitigation.
  2. Document risk management ✓
    The missing lifecycle process is precisely the documented risk-management control required for the assumed high-risk system.
  3. Increase user disclosures
    More disclosures would not create the absent process for identifying, evaluating, and mitigating foreseeable system risks.
  4. Publish training-data summaries
    Training summaries may relate to general-purpose model duties, but they do not replace a high-risk risk-management process.
The trap
A test report is not equivalent to a documented risk-management system covering identification, evaluation, and mitigation.

How to remember it

The absent evidence is a documented lifecycle risk-management process, not additional disclosure, training summaries, or monitoring alone.

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