Operate a risk-management process and appropriate data: Which sequence best reflects the EU AI Act's
Risk management, data governance, technical documentation, and conformity assessment must all be completed before a high-risk system is placed on the market.
The question
A provider is preparing an Annex III high-risk hiring system for the EU market and must satisfy the core requirements around risk management, data governance, documentation, and conformity assessment. Which sequence best reflects the EU AI Act's expectations before placing it on the market?
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- Place the system on the market first to gather real usage, then retroactively build the technical documentation and run the conformity assessment once enough live data has accumulated.Plausible-sounding but the conformity assessment and documentation must be completed before market placement, not assembled retroactively from live use.
- Rely on a signed customer contract accepting the risks in place of a conformity assessment, since a deployer's written acknowledgment substitutes for the provider's pre-market obligations.Almost plausible because contracts allocate risk, but a customer's acknowledgment cannot replace the provider's mandatory pre-market conformity assessment.
- Publish a public transparency notice describing the model and treat that disclosure as fulfilling the data-governance, documentation, and conformity-assessment requirements together.Plausible but a transparency notice is not a substitute for the distinct data-governance, documentation, and conformity-assessment duties, which must each be met.
- Operate a risk-management process and appropriate data governance, compile the technical documentation, and complete the conformity assessment before the system is placed on the market. ✓Correct: the Act requires risk management, data governance, technical documentation, and a completed conformity assessment prior to placing a high-risk system on the market.
The trap
Thinking a contract, a public notice, or post-launch data can substitute for a pre-market conformity assessment. How to remember it
Risk management, data governance, technical documentation, and conformity assessment must all be completed before a high-risk system is placed on the market.
How many of these would you get right?
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