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 being deployed in 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 together 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 (ICM). The specification is given as eleven requirements in normative form, each traced to a legal obligation or to a physical constraint and each accompanied by a conformance procedure that a third party can execute on a real installation. The applicability of the artificial intelligence framework is treated as a conditional question, and the requirements are constructed so that they survive either outcome. Three constraints are derived in closed form. The response time of a fleet level monitor on a wireless link places it outside any reaction loop, which excludes it from the class of automatic safety functions. A check decides on a difference between an observation and a sealed reference, so the smallest deviation it can resolve is fixed by the part of the systematic measurement uncertainty that does not remain common to the two, which no amount of averaging reduces and which the calibration regime bounds. A single commissioning cycle taken during the start up transient widens the reference envelope by at least D/√n and disables a band check whenever D > d√n/k. Both corresponding failure modes are silent: the monitor appears to operate, the record fills with conforming entries, and nothing could have been seen. The document contains no empirical validation, and states why: a validation resting on assumed parameters would have the appearance of evidence without the substance, which is the failure mode the specification exists to prevent. Questions requiring field data are stated so that others may answer them.