Valid Compliance Evidence for Fleets of Autonomous Robots: Independent Conformance Monitoring under Regulation (EU) 2023/1230 and Directive (EU) 2024/2853

14 August 2026, Version 1
This content is an early or alternative research output and has not been peer-reviewed by Cambridge University Press at the time of posting.

Abstract

Autonomous mobile robots, including humanoid robots, are entering industrial plants faster than the standards written for them. No published type C safety standard covers dynamically stable industrial mobile robots, while Regulation (EU) 2023/1230, Regulation (EU) 2024/1689 and Directive (EU) 2024/2853 attach a defined legal consequence to the absence of evidence about how a machine behaved. This document specifies the component that produces that evidence, the Independent Conformance Monitor: eleven requirements in normative form, each traced to a legal obligation or a physical constraint and each with a conformance procedure a third party can execute. Three constraints are derived in closed form. Response time places the monitor outside any reaction loop. Calibration, not averaging, bounds the smallest deviation a check can resolve. A reference established during the start up transient can disable a check silently, leaving a record that appears conforming. No empirical validation is offered, and the document states why.

Keywords

autonomous robots
human oversight
EU Machinery Regulation
AI Act
product liability
humanoid robots

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