FAQEU AI Act

EU AI Act What belongs in the technical file?

High-risk AI providers must prepare before market placement or first use and keep it current. Article 11 sets the duty; Annex IV lists the minimum contents.

Document what the system does, how it was built and tested, its risks and controls, and how it will be monitored after release.

Author
Sorena AI
Published
May 9, 2026
Updated
Oct 21, 2026
Overview

Use Annex IV to organise the for a high-risk AI system. The file must let authorities and notified bodies assess compliance. A project memo or model document serves a different purpose. Under the 2026 amendment, Article 11 applies from 2 December 2027 for Annex III systems and 2 August 2028 for Annex I systems. The amendment was published on 24 July 2026 and entered into force on 27 July.

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3 of 3 questions
Question 1

What does Article 11 require?

Prepare the file before placing the high-risk system on the market or putting it into service. Keep it current and show how the system meets the requirements in Chapter III Section 2.

An authority or notified body should be able to understand the system from the file. Start with identity and , then connect the design, data, tests, risk controls, oversight, cybersecurity, conformity and monitoring evidence to that purpose.

Apply Annex IV items as relevant to the system. If an item does not apply, record the facts and reason in the file.

  • Identify the AI system, provider, version, deployment form, , and relevant software, firmware, hardware, API, or embedded-product context.
  • Explain the system architecture, development process, algorithms, design choices, assumptions, expected outputs, output quality, and any third-party pre-trained systems or tools used.
  • Document training, validation, and testing data where relevant, including provenance, scope, main characteristics, selection, labelling, cleaning, and data-governance choices.
  • Include validation and testing procedures, metrics for accuracy and robustness, discrimination-impact checks where relevant, test logs, and dated reports signed by responsible persons.
  • Tie the file to the Article 9 risk-management system, Article 14 human-oversight measures, cybersecurity measures, conformity evidence, and post-market monitoring plan.

Must the file follow Annex IV?

Annex IV is the minimum content baseline for a high-risk system subject to Article 11, applied as relevant. Small and medium-sized enterprises (SMEs), including startups, and small mid-cap enterprises may provide the elements through the simplified Commission form under amended Article 11. They must still supply the applicable information.

Is a legal memo enough?

No. Annex IV expects engineering and product evidence: system description, , interfaces, architecture, development methods, data requirements, validation and testing procedures, performance metrics, cybersecurity measures, risk management, lifecycle changes, standards or technical specifications, conformity declaration, and post-market monitoring.

When does the documentation duty apply?

Regulation (EU) 2026/1744, published on 24 July 2026 and entering into force on 27 July 2026, moves Chapter III Sections 1 to 3, except Article 6(5), to 2 December 2027 for Article 6(2) Annex III systems and 2 August 2028 for Article 6(1) Annex I systems. Article 111 separately limits how the high-risk rules apply to a system placed on the market or put into service before the relevant date, with a 2 August 2030 deadline for high-risk systems intended for use by public authorities.

Question 2

What system and testing evidence belongs in the file?

Annex IV starts with the system and how it is supplied, then how it was built. Later parts cover testing, controls, monitoring, changes and conformity evidence.

Link claims to records people can check: requirements, architecture diagrams, dataset sheets, test reports, risk-control registers, release notes, instructions and the conformity file. Cover purpose, data, model behaviour, oversight, security, performance and residual risk.

The provider remains responsible for the Article 11 file when the system includes third-party components or pretrained systems. Connect supplier records to the final , integration choices, tests, limitations and controls.

  • System identity: provider name, system name, version, relation to prior versions, , deployment form, user interface, instructions for use, and hardware or software interactions.
  • Architecture and development: software components, model or algorithm logic, design choices, assumptions, optimization targets, expected output quality, computational resources, third-party systems, and integration or modification decisions.
  • Data: training methodologies and techniques, training datasets, provenance, scope, main characteristics, collection and selection methods, labelling, cleaning, and data-quality gaps that affect compliance.
  • Validation and testing: procedures, validation and test data, metrics for accuracy and robustness, checks against Chapter III Section 2 requirements, discriminatory-impact assessment, signed reports, and test logs.
  • Controls: human-oversight measures, interpretability support for deployers, input-data specifications, cybersecurity measures, risk-management description, lifecycle changes, and post-market performance evaluation.

How detailed must testing evidence be?

Annex IV calls for validation and testing procedures, information about validation and testing data and their main characteristics, metrics used for accuracy, robustness, compliance with high-risk requirements, and potentially discriminatory impacts, plus test logs and dated reports signed by responsible persons.

Where do oversight and cybersecurity belong?

They belong in the Annex IV development and control evidence. The record should assess the human-oversight measures needed under Article 14, identify technical measures that help deployers interpret outputs, and describe the cybersecurity measures put in place for the system.

Question 3

How do standards, conformity and monitoring fit?

List the harmonised standards applied in full or in part whose references appear in the Official Journal of the European Union. If none is applied, describe the solutions used to meet the high-risk requirements and list other relevant standards and technical specifications.

Include the EU declaration of conformity and describe how you evaluate performance after release. Article 72 makes the monitoring plan part of the Annex IV .

Article 18 requires the provider to keep technical and quality-management documentation, applicable notified-body records and the declaration available to national authorities for 10 years after market placement or first use. Logs have a separate rule under Articles 19 and 26: keep automatically generated logs under your control for an appropriate period of at least six months, unless EU or national law provides otherwise, particularly personal-data law.

Decision (EU) 2026/2274 cited EN 18286:2026 in the Official Journal on 14 October 2026. Annex ZA maps clause 8.9.2 to the first sentence of Article 11(1), provided the file contains every Annex IV element. Record the clauses applied, conditions, system version and evidence. The presumption of conformity covers only those requirements; keep the complete technical file and evidence of other applicable duties.

  • Standards register: list Official Journal-referenced harmonised standards used in full or in part, and map each one to the AI Act requirement it supports.
  • Alternative solutions: where no is used, document the technical or organisational solution adopted for the relevant Chapter III, Section 2 requirement.
  • Conformity file: include the EU declaration of conformity and keep it aligned with system identity, provider identity, applicable Union law, and any standards or common specifications cited.
  • Post-market plan: describe how performance data, deployer feedback, incidents, lifecycle changes, and interactions with other AI systems will be collected and analysed to evaluate continued compliance.
  • Change control: record relevant lifecycle changes and reassess whether the , conformity route, or notified-body assessment needs an update.

Do standards replace the technical file?

No. Standards can support conformity, and harmonised standards referenced in the Official Journal can create a presumption of conformity for the requirements they cover, but Annex IV still requires the itself, including the standards list or alternative compliance solutions.

Is the monitoring plan part of the file?

Yes. Article 72 makes the post-market monitoring plan part of the Annex IV .

Primary sources

References and citations

digital-strategy.ec.europa.eu2 citations
Referenced sections
  • Commission implementation overview for the AI Act's risk-based structure and provider obligations for high-risk AI systems.
  • Commission overview confirming that high-risk AI providers must address documentation, human oversight, robustness, cybersecurity, conformity assessment, registration, declaration of conformity, and CE marking.
"risk-based rules for AI developers and deployers"
More quoted passages
"The AI Act defines 4 levels of risk"
digital-strategy.ec.europa.eu2 citations
Referenced sections
  • Commission source for the role of harmonised standards, voluntary standards use, and the standards-development context for high-risk AI systems.
  • Commission page explaining that harmonised standards translate AI Act requirements into technical language and that applying standards remains voluntary.
"Standards translate legal requirements into common technical language"
More quoted passages
"The application of standards remains voluntary"
ai-watch.ec.europa.eu2 citations
Referenced sections
  • JRC source for the presumption-of-conformity role of European harmonised standards when published in the Official Journal.
  • JRC brief explaining that European harmonised standards published in the Official Journal provide a legal presumption of conformity with the AI Act.
"published in the Official Journal of the European Union"
More quoted passages
"provides a legal presumption of conformity"
eur-lex.europa.eu
Referenced sections
  • Primary source for Article 11, Annex IV, Article 47, Annex V, Article 72, and the high-risk AI requirements referenced by technical documentation.
"The technical documentation of a high-risk AI system"
eur-lex.europa.eu
Referenced sections
  • Primary legal text listing the system description, architecture, data, validation, testing, oversight, cybersecurity, risk-management, standards, conformity, and post-market items required in technical documentation.
"shall contain at least the following information"
eur-lex.europa.eu
Referenced sections
  • Primary legal text requiring standards or alternative-solution evidence, a copy of the EU declaration of conformity, and a post-market monitoring plan within technical documentation.
"The post-market monitoring plan shall be part"
eur-lex.europa.eu
Referenced sections
  • Primary legal text for the Article 11 timing rule and Annex IV minimum technical-documentation contents for high-risk AI systems.
"before that system is placed on the market"
eur-lex.europa.eu
Referenced sections
  • Binding amendment published on 24 July 2026, entering into force on 27 July 2026, which extends the simplified Article 11 form to small mid-cap enterprises and moves the Chapter III application dates.
"SMEs, including start-ups, and SMCs"
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