Art.9: Risk Management System
Continuous, documented risk-management process for high-risk AI.
Last reviewed October 2026
Why Art.9 evidence is hard
An assessor asks to see a process that runs continuously, not a snapshot. Penaxtra does not run your risk-management system and no probe reports on it. What it supplies as evidence inside one is the recurring part: a dated ledger of every probe attempted against each endpoint, findings that hold their identity across scans so a reopened issue is visibly a reopen, and an accepted-risk register that survives re-observation instead of quietly reverting to open. None of that is the risk-management system itself.
How Penaxtra maps to Art.9
The EU AI Act Art.9 identifier is attached at creation, so a finding reaches the evidence export already in the structure an assessor reads. Twenty-five cross-framework overlap pairs are pre-computed, so where this same weakness also lands on another framework, that control identifier rides the same finding instead of being re-derived. Every finding carries the probe that was sent, a SHA-256 digest of the response it provoked, the tier that decided the verdict and its status history from first observation to close. Identity survives a re-scan: a control you closed and that comes back reopens under the same row with a reopen count, rather than arriving as a new issue.
Art.9 capabilities
Findings tagged with the EU AI Act Art.9 identifier
Penaxtra severity for this control (critical)
Cross-framework identifiers attached to the same finding where controls overlap
PDF and JSON evidence export with the control identifier attached
Art.9 control coverage
Findings for Art.9 carry the EU AI Act Art.9 identifier along with the corresponding control identifiers in the other frameworks Penaxtra maps, so one result is reflected across each mapped framework.
Frequently asked
What is Art.9 (Risk Management System)?
Continuous, documented risk-management process for high-risk AI. It is an EU AI Act control; Penaxtra assesses it at critical severity.
How does Penaxtra test for Art.9?
The EU AI Act Art.9 identifier is attached at creation, so a finding reaches the evidence export already in the structure an assessor reads. Twenty-five cross-framework overlap pairs are pre-computed, so where this same weakness also lands on another framework, that control identifier rides the same finding instead of being re-derived. Every finding carries the probe that was sent, a SHA-256 digest of the response it provoked, the tier that decided the verdict and its status history from first observation to close. Identity survives a re-scan: a control you closed and that comes back reopens under the same row with a reopen count, rather than arriving as a new issue.
Does a finding for Art.9 help with an audit?
Each finding is tagged with the EU AI Act Art.9 identifier and exported in the PDF and JSON evidence pack, so it appears on the auditor control list with the identifier already attached.