The board names who owns safety, the right to stop, incident learning, deployment limits, and the P&L of a commercial civil autonomous system — or the house withholds the seat. Not a model builder. Not a CRO. Not a UAV CEO.
Christian Pobbig and Beyond Chiefs work from Hamburg on AI Executive Search in DACH. The operator file is not the seat. The high-risk stop is not the seat. The AI Act does not require a Vorstand seat. Not every warehouse is high-risk. Switzerland: unknown.
Safety. The right to stop. Incident learning. Deployment limits. The P&L. Miss one, and the house withholds the title. The law does not create an office for autonomous systems. Whether any DACH supervisory board has already named this owner: unknown. Switzerland: not opened.
The operator guide for driverless transport systems, September 2024 edition, industry and VDI working-group status, not a statute: “Die Verantwortung für die hier genannten Punkte bleibt immer beim Betreiber. Er kann diese nicht abgeben oder abtreten.” Responsibility does not start at the transfer of risk. It starts at selection and planning of the work equipment. A CE mark does not discharge the hazard assessment. Substantial change, as the guide reads it, not as a statute quote: the operator converts in-house and becomes the manufacturer; or the operator designs the concept and has a third party convert, and still keeps manufacturer responsibility; a supply situation needs a contract that states who holds the manufacturer role (Forum-FTS guide 2024).
DGUV: as a rule the employer must ensure that use of driverless industrial trucks stays safe to the state of the art for the whole period of use. Outdoor use, whether a stop can be reached, and mixed fleets are deployment-domain problems the risk assessment has to close — not a checklist and not a live cell (DGUV FAQ).
Sirris, 23 May 2023, under the Machinery Directive, not as the house’s adviser: CE marking covers the vehicle, not the system. Safety of industrial robot installations ultimately rests with the user, who may use the system only as intended (Sirris). “Rests with the user” is not German organ liability.
Not every commercial autonomous system is high-risk. Whether a given warehouse or mobility system is high-risk: unknown. Article 14 and Article 26 are that boundary, not a Vorstand statute.
High-risk systems shall be overseen by natural persons while in use. The person assigned oversight must be enabled, as appropriate and proportionate, to decide not to use the system or to disregard, override or reverse the output, and to interrupt it through a stop or a similar procedure that brings it to a halt in a safe state (AI Act Service Desk, Art. 14). The desk’s own summary is not legally binding. The two-person check for remote biometric identification is out.
Deployers assign human oversight to natural persons who have competence, training and authority, and the necessary support. If use in line with the instructions may present a risk within the meaning of Article 79(1), they inform the provider or distributor and the relevant market-surveillance authority without undue delay, and suspend use. A serious incident is notified immediately, first to the provider, then to the importer or distributor and the market-surveillance authorities (AI Act Service Desk, Art. 26). The statute names a natural person at the machine — not a board owner of limits, learning and P&L.
Use the system outside the declared limits — temperature, floor, zone — and the house has left the contract. That is the product-liability hinge, without an article number: software, including AI systems, can be a product; a company that substantially modifies a product outside the manufacturer’s control and then places it on the market or puts it into service can be treated as manufacturer (SKW Schwarz, 19 Dec 2024). A picking system specified for a stated temperature and a level industrial floor, used in a cold store or on an uneven floor: the operator left the declared envelope (Taylor Wessing, 11 May 2026). No SAE driving levels. No acronym treated as the directive’s word.
The nearest board analog, wrong object, no DACH filing: who has the authority to stop this, and how fast can they act? The gap is often not a missing policy. It is a missing name (Corporate Board Member, 3 Sep 2026). That field is software decisions affecting customers, employees, capital or reputation — not a physical autonomous system.
Cost, utilisation, margin: unknown. The name owns the judgment. A figure does not belong on this page. Extensive further training of the model is a liability hinge, not a job.
The safety case, the stop, and the change to a live cell are a different contract. The operator file of a civil drone business, approval and remote pilot, is a different contract. Deployment limits here are the ground or plant envelope, not an airspace file. Not a model builder. No weapons, no military detail, no incident without a primary record.
A named person with authority — in the high-risk case, the natural person at the machine. The board names who owns the right to stop for the system, or withholds the seat. The file alone is not that name.
No. That is unknown until the specific system is classified. Articles 14 and 26 apply as a boundary, not as an office.
No. The seat holds safety, the stop, learning, deployment limits, and the P&L together. The model builder builds the model.
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