Update the risk file through the system lifecycle | AIGP
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Update the risk file through the system lifecycle: Which documentation approach best satisfies the EU AI Act

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

EU high-risk documentation should evolve through the lifecycle, connecting changing data, monitoring, risks, controls, and mitigation decisions.

The question

Assume the relevant EU AI Act duties apply. A housing administrator operates a high-risk system that ranks applications. Its risk file was written before deployment and has not changed despite new applicant data, identified performance concerns, and altered operating procedures. Which documentation approach best satisfies the EU AI Act risk-management expectation?

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  1. Append each major issue while leaving the original assessment and controls unchanged.
    Recording issues without revisiting assumptions and controls leaves the assessment disconnected from current risks and mitigations.
  2. Retain the original risk file after approval.
    Initial approval does not make a risk file sufficient when data, performance concerns, and operating procedures change.
  3. Record the latest concern and rely on existing monitoring and procedures unless another incident occurs.
    A single record and passive reliance on existing procedures do not demonstrate iterative risk evaluation, control updates, and mitigation.
  4. Update the risk file through the system lifecycle. ✓
    The file should remain current and connect changing risks, data, controls, monitoring, and mitigation decisions throughout operation.
The trap
Look for iterative evidence connecting changing risks to controls and monitoring.

How to remember it

EU high-risk documentation should evolve through the lifecycle, connecting changing data, monitoring, risks, controls, and mitigation decisions.

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