This is one of the mostly widely misunderstood concepts in the NLF. If you think harmonised standards provide presumption of conformity, you are wrong, and this article is for you!
Brilliant clarification on what practitioners consistently get wrong about harmonised standards. The timing issue you highlight between standard publication and OJEU citation is especially critical for organizations trying to build AI Act compliance programs right now. They're essentially operating in a gap where JTC 21 standards exist in draft form but can't yet provide presumption of conformity. Your point about prEN 18286's deliberate avoidance of normative references is fascinating because it reveals a strategic architectural choice about maintaining flexibility versus creating hard dependencies. I wonder how market surveylance authorities will treat organizations that voluntarily adopt pre-OJEU standards with strong documentation versus those waiting for official citation.
Compliance with standards that are not cited, whether harmonised standards or not, contributes to the elimination of risks and non-compliance. This should be taken into account by a market surveillance authority, to the extent that it helps comply with the legal obligations.
Brilliant clarification on what practitioners consistently get wrong about harmonised standards. The timing issue you highlight between standard publication and OJEU citation is especially critical for organizations trying to build AI Act compliance programs right now. They're essentially operating in a gap where JTC 21 standards exist in draft form but can't yet provide presumption of conformity. Your point about prEN 18286's deliberate avoidance of normative references is fascinating because it reveals a strategic architectural choice about maintaining flexibility versus creating hard dependencies. I wonder how market surveylance authorities will treat organizations that voluntarily adopt pre-OJEU standards with strong documentation versus those waiting for official citation.
Compliance with standards that are not cited, whether harmonised standards or not, contributes to the elimination of risks and non-compliance. This should be taken into account by a market surveillance authority, to the extent that it helps comply with the legal obligations.