DISC InfoSec blogEU AI Act concerning Risk Management Systems for High-Risk AI

Aug 05 2025

EU AI Act concerning Risk Management Systems for High-Risk AI

Category: AI,Risk Assessment — disc7 @ 11:10 am

Lifecycle Risk Management
Under the EU AI Act, providers of high-risk AI systems are obligated to establish a formal risk management system that spans the entire lifecycle of the AI system—from design and development to deployment and ongoing use.
Continuous Implementation
This system must be established, implemented, documented, and maintained over time, ensuring that risks are continuously monitored and managed as the AI system evolves.
Risk Identification
The first core step is to identify and analyze all reasonably foreseeable risks the AI system may pose. This includes threats to health, safety, and fundamental rights when used as intended.
Misuse Considerations
Next, providers must assess the risks associated with misuse of the AI system—those that are not intended but are reasonably predictable in real-world contexts.
Post-Market Data Analysis
The system must include regular evaluation of new risks identified through the post-market monitoring process, ensuring real-time adaptability to emerging concerns.
Targeted Risk Measures
Following risk identification, providers must adopt targeted mitigation measures tailored to reduce or eliminate the risks revealed through prior assessments.
Residual Risk Management
If certain risks cannot be fully eliminated, the system must ensure these residual risks are acceptable, using mitigation strategies that bring them to a tolerable level.
System Testing Requirements
High-risk AI systems must undergo extensive testing to verify that the risk management measures are effective and that the system performs reliably and safely in all foreseeable scenarios.
Special Consideration for Vulnerable Groups
The risk management system must account for potential impacts on vulnerable populations, particularly minors (under 18), ensuring their rights and safety are adequately protected.
Ongoing Review and Adjustment
The entire risk management process should be dynamic, regularly reviewed and updated based on feedback from real-world use, incident reports, and changing societal or regulatory expectations.

🔐 Main Requirement Summary:

Providers of high-risk AI systems must implement a comprehensive, documented, and dynamic risk management system that addresses foreseeable and emerging risks throughout the AI lifecycle—ensuring safety, fundamental rights protection, and consideration for vulnerable groups.

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