Corrective action procedures
Description
Article 16(j) — Provider takes corrective action where the AI system poses risk; informs distributors, deployers, and authorities.
⚠️ Risk Impact
When an AI system is discovered to pose risk in deployment, time-to-correction matters. Slow corrective action expands the population affected and the regulator's measure of harm.
🔍 How EchelonGraph Detects This
EchelonGraph's Tier 1 Cloud Scanner automatically checks for this condition across all connected cloud accounts. Violations are flagged as high-severity findings with remediation guidance.
🔧 Remediation
Document corrective-action procedures: triggers (incident reports, drift alerts, deployer feedback), severity classification, response timeline, notification cascade (deployers + distributors + national authorities), and recall/disable mechanisms.
💀 Real-World Attack Scenario
A vendor's AI résumé-screener was found by a journalist to systematically downscore candidates with non-Western names. The vendor's response: 'we'll fix it in next quarter's retrain.' Public outcry; the AP picked it up; 14 affected deployers immediately disabled the system. Article 16(j) probe followed: vendor lacked corrective-action procedure for in-the-wild fairness failures.
💰 Cost of Non-Compliance
Article 16(j) corrective-action gap: up to €15M / 3% revenue. Cumulative reputational cost: avg $4-8M per incident (Edelman Trust Barometer 2024).
📋 Audit Questions
- 1.Walk me through your corrective-action procedure end-to-end.
- 2.When was the last corrective action triggered? What was the response time?
- 3.How are deployers and authorities notified — and within what timeframe?
- 4.What is your recall/disable capability for a high-risk system?
⚡ Common Pitfalls
- ⛔No documented triggers for corrective action — relying on ad-hoc judgement
- ⛔Notification cascade omits national authorities — falling foul of Article 72 reporting obligations
- ⛔Recall/disable capability untested — works in theory, fails in production
📈 Business Value
Documented corrective-action procedure is the difference between regulator probe ('they responded appropriately') and consent order ('they failed to act'). Material in EU AI Act + customer-trust defence.
⏱️ Effort Estimate
3-4 weeks for procedure authoring + tabletop rehearsal
EchelonGraph integrates corrective-action triggers + auto-notification cascades
🔗 Cross-Framework References
Automate EU AI Act ART16-CORRECTIVE compliance
EchelonGraph continuously monitors this control across all your cloud accounts.
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