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EU AI Act

Building Infrastructure for High-Risk AI Systems Under the AI Act

High-risk AI systems require risk management, data governance, monitoring, and human oversight. Here's the infrastructure architecture for each requirement.

Luca Berton8 min read

If your AI system falls under Annex III of the AI Act — credit scoring, recruitment, medical devices, critical infrastructure management, law enforcement, education — you need infrastructure that satisfies Articles 8-15. Here's the architecture for each requirement.

Article 9: Risk Management System

A continuous, iterative process throughout the AI system lifecycle:

  • Risk identification pipeline — Automated scanning for known risks: bias in training data, adversarial vulnerability, performance degradation on edge cases
  • Risk quantification — Metrics dashboards showing risk levels across fairness, safety, robustness dimensions
  • Risk mitigation tracking — Integration with issue tracking (Jira, Linear) for risk-to-remediation workflow
  • Residual risk documentation — Automated capture of accepted risks with justification

Article 10: Data and Data Governance

  • Data quality infrastructure — Great Expectations, Deequ, or custom validation pipelines running on every data ingestion
  • Bias detection — Automated demographic parity, equalized odds, and calibration analysis on training datasets
  • Data lineage — End-to-end tracking from source to feature to model prediction (Apache Atlas, OpenLineage)
  • Annotation quality management — Inter-annotator agreement monitoring, annotation audit trails
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Article 13: Transparency and Information

  • Instructions for use generation — Auto-generated documentation of system capabilities, limitations, intended use
  • Performance disclosure — Automated accuracy, precision, recall reporting across relevant subgroups
  • Explainability infrastructure — SHAP, LIME, or attention-based explanations served alongside predictions

Article 14: Human Oversight

  • Human-in-the-loop (HITL) infrastructure — Review queues, approval workflows, override interfaces
  • Confidence-based routing — Low-confidence predictions automatically routed to human reviewers
  • Kill switch infrastructure — Ability to disable AI system immediately, with fallback to non-AI process
  • Override tracking — Log every human override for analysis and model improvement
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18+ years experience · Ex-Red Hat & Dell · Speaker at KubeCon EU 2026

Luca Berton

Written by

Luca Berton

CEO at Open Empower. 18+ years building enterprise infrastructure at JPMorgan Chase, Red Hat & Dell. Author of 9 technical books. Speaker at Red Hat Summit and KubeCon EU 2026. Instructor on Coursera, Pluralsight & Udemy.

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