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

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.

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Publication Details

Published
2026-08-14
DOI
https://doi.org/10.33774/coe-2026-v35tj
Primary Topic
Safety Systems Engineering in Autonomy
Type
preprint
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Valid Compliance Evidence for Fleets of Autonomous Robots: Independent Conformance Monitoring under Regulation (EU) 2023/1230 and Directive (EU) 2024/2853

Marco Galli
Safety Systems Engineering in Autonomy
preprint

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

Marco Galli
preprint en

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.

Safety Systems Engineering in Autonomy
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Valid Compliance Evidence for Fleets of Autonomous Robots: Independent Conformance Monitoring under Regulation (EU) 2023/1230 and Directive (EU) 2024/2853 — Marco Galli · (2026) | TGRS Research Map | TGRS