EU AI Act Article 9 vs Article 12: What Each One Actually Requires
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If you're building or operating a high-risk AI system under the EU AI Act, this is the distinction that trips up almost every compliance program: having a risk framework and being able to prove it operated are two different obligations, in two different articles, and most teams only build one of them. TL;DR Article 9 requires a continuous risk management process for high-risk AI systems — identify risks, evaluate them, mitigate them, review them as the system changes. Article 12 requires…
1Key Takeaways
- If you're building or operating a high-risk AI system under the EU AI Act, this is the distinction that trips up almost every compliance program: having a risk framework and being able to prove it operated are two different obligations, in two different articles, and most teams only build one of them.
- TL;DR Article 9 requires a continuous risk management process for high-risk AI systems — identify risks, evaluate them, mitigate them, review them as the system changes.
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3Why it matters
Coding AI shifts how fast software ships and how much human review each change needs. DEV — AI reports that if you're building or operating a high-risk AI system under the EU AI Act, this is the distinction that trips up almost every compliance program: having a risk framework and being able to prove it operated are two different obligations, in two different articles, and most teams only build one of them.
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