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EU AI Act · Engineering reference

Article 9 — Risk Management System

High-risk AI systems must operate within a continuous, documented risk-management system spanning the entire AI lifecycle.

Audit-survivable
31%
of 50 EU-exposed enterprises in MindMap's 2026 readiness benchmark

What the Article requires

Article 9 requires providers of high-risk AI systems to establish, implement, document and maintain a risk-management system that runs throughout the AI lifecycle. The system identifies foreseeable risks to health, safety and fundamental rights, evaluates risks under intended use and reasonably-foreseeable misuse, and adopts targeted risk-management measures. Critically, it is not a one-time exercise — the system is updated continuously as the AI evolves.

In engineering terms

Maps to existing enterprise risk-management frameworks but specifically extends to AI lifecycle artefacts: training-data risks, model behaviour risks, deployment-context risks, and misuse risks. Engineering teams typically bolt this onto SR 11-7 (US BFSI), the FCA SYSC framework, or analogous existing-risk taxonomies.

Compliance checklist

  • ✓Documented risk-management process specifically applied to AI systems
  • ✓Identified, evaluated and treated risks to health, safety and fundamental rights
  • ✓Risk-management decisions documented with rationale
  • ✓Continuous-update cycle, not a one-time assessment
  • ✓Integration with the existing enterprise risk function

Terms used here

EU AI ActAnnex III high-risk AI

All Articles in the reference · The EU AI Act compliance architecture

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The EU AI Act Readiness Kit puts this checklist, and the other 13 Articles', into one fill-in PDF with room for an owner, evidence location and target date on every item. Plus an AI system inventory, a classification record, an Annex IV outline and a FRIA template.

  • 01How to use this kit. Four steps, and which checklists apply to each classification result.
  • 02AI system inventory. One row per AI system: owner, what it does, built or bought, your role and its classification.
  • 03Classification record. The five questions from our applicability checker, with space for answers, notes and the result.
  • 04Evidence checklists. 72 evidence items across Articles 9 to 15, 25, 26, 27, 50, 53, 55 and 72, each with an owner, evidence location and target date.
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