AM-138
← Back to ledgerHolding·last review5 May 2026
The 2 August 2026 EU AI Act deployer-obligations enforcement window adds three new clause families to the AI MSA red-team checklist that were optional or absent in pre-enforcement contracts: Article 11 technical-file pass-through, Article 16 post-market-monitoring support, and Article 26 deployer-documentation supply. The post-enforcement checklist grows from the 38-item RES-005 v1.0 baseline to roughly 54 items across 11 clause families, with Article 50 transparency UX (covered at AM-135) and foundation-model uptime hard-dollar liability (covered at AM-136) as additional 2026 additions. The asymmetric-instrument observation — that enterprise and operator AI procurement face the same vendor-citation-chain manipulation pattern with different audit instruments — is embedded as a 600-word insert in this piece.
Companion to RES-005 update v1.1 scheduled August-September 2026 after the first 30-60 days of enforcement reveal which clause additions are operationally load-bearing. Cadence 60-day with first review immediately after enforcement window opens. Carries the asymmetric-instrument bridge insert that was originally a standalone bridge piece. Sister claims: AM-135 (Article 50), AM-136 (uptime), AM-026 (60-question RFP), AM-046 (Article 12 audit substrate), RES-005 (MSA red-team checklist), AM-139 (vendor case-study citation chain bridge).
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