docs/qms/sop_incident_response.md: wrong detail — report serious incidents to relevant authority within **15 days** / **Timeline:** Within 15 days of becoming aware (DOC-BLEGAL-008) #131

Wave 1 · theme D1-10: Documentation-only fixes · highest severity High · 1 finding(s) · effort docs fix

Summary

Following the SOP, a provider would report a death or a critical-infrastructure disruption days after the legal deadline.

Primary finding

DOC-BLEGAL-008 — docs/qms/sop_incident_response.md: wrong detail — report serious incidents to relevant authority within 15 days / Timeline: Within 15 days of becoming aware

severity High

Where. docs/qms/sop_incident_response.md:67, docs/qms/sop_incident_response.md:294 (Turkish mirror: docs/qms/sop_incident_response-tr.md:67, docs/qms/sop_incident_response-tr.md:293) · type: wrong detail

The document says. report serious incidents to relevant authority within 15 days / Timeline: Within 15 days of becoming aware

What the code does. Art. 73(2): report 'immediately after the provider has established a causal link ... or the reasonable likelihood of such a link, and, in any event, not later than 15 days' after awareness. Art. 73(3): for a widespread infringement or a serious incident under Art. 3(49)(b) (critical infrastructure), 'immediately, and not later than two days'. Art. 73(4): in the event of a death, 'not later than 10 days'.

User impact. Following the SOP, a provider would report a death or a critical-infrastructure disruption days after the legal deadline.

Proposed correction. Report immediately once a causal link (or its reasonable likelihood) is established, and in any event: within 2 days for a widespread infringement or a serious incident under Art. 3(49)(b) (critical infrastructure); within 10 days in the event of a person's death; otherwise within 15 days of becoming aware (EU AI Act Art. 73(2)-(4)).

Turkish mirror. the Turkish page has the same error; fix both in the same PR

Acceptance criteria

• Each statement is re-checked against the code at fix time.
• Documentation listed above is corrected in English and in its Turkish mirror in the same PR.
• Every finding in this issue is resolved or explicitly closed with a reason.

_{Found by the October 2026 ForgeLM code and documentation review against commit cab2947. Code links point at that commit; line numbers may have moved since. Finding IDs (CR-…, DOC-…, TECH-…) are stable references for this backlog.}