Requirements GuideEU

EU AI Act High-risk requirements

High-risk providers must meet system requirements before supply. Deployers must use and monitor the system under the provider's instructions.

See what to build, what to document and what to check during use under Articles 8-16 and 26.

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

For a , Articles 8-15 set the system requirements, Article 16 assigns provider duties, and Article 26 sets deployer duties. Start with the correct classification, sector rules and application date, then use the evidence lists below.

Section 1

What providers must do

Check the product-law route before assigning duties. Annex I Section A products may need both AI Act high-risk controls and sector-law controls. Section B products follow amended Article 2(2): only Article 6(1), Article 60a and Articles 102-112 apply directly. Articles 57-59 apply only where high-risk requirements have been integrated into sector law.

For Section A, an Article 2(13) limitation needs an applicable delegated act; existing sector controls alone do not establish an exemption.

Article 8 is the gateway: high-risk AI systems must comply with the requirements in Section 2, taking account of the system's intended purpose and the state of the art.

For product-regulated systems, the AI Act requirements can be integrated with existing product documentation and testing where the product is also covered by Union harmonisation legislation.

Article 16 then turns those requirements into provider obligations. The provider must meet Section 2 requirements, identify itself on the system or accompanying documentation, and maintain quality management. Keep required documentation and logs under provider control. Complete the assessment, declaration, CE marking and registration where required.

Take corrective action, demonstrate conformity to authorities and meet applicable accessibility requirements.

For systems supplied or first used before their Chapter III application date, amended Article 111(2) applies the high-risk operator rules only if significant design changes occur from that date. Annex X large-scale IT systems follow the separate rule in Article 111(1).

Chapter III Sections 1-3, except Article 6(5), apply from 2 December 2027 for Article 6(2) Annex III systems and 2 August 2028 for Article 6(1) Annex I systems.

This transition rule uses a different test from the Article 43 substantial-modification rule that reopens conformity assessment, so record the first placement or service date, type and model, change description, and legal test instead of treating every software update alike.

Article 111(2) also requires providers and deployers of high-risk systems intended for public-authority use to take the necessary steps to comply by 2 August 2030.

Article 17 governs the provider quality management system alongside the Section 2 system requirements. EN 18286:2026 was cited in the Official Journal on 14 October 2026. Its presumption of conformity is limited to covered requirements and Annex ZA conditions; keep separate evidence for uncovered obligations and for the system requirements in Articles 8-15.

  • Article 9: maintain a documented lifecycle risk management system for intended use and reasonably foreseeable misuse.
  • Articles 4a and 10: govern training, validation, and testing data for suitability, representativeness, bias detection, data gaps, and safeguards where special-category personal data is strictly needed for bias correction.
  • Article 11 and Annex IV: prepare and keep up-to-date technical documentation before market placement or putting into service.
  • Article 12: design logging capabilities that support traceability, post-market monitoring, and deployer monitoring duties.
  • Articles 13-15: provide deployer instructions, human oversight measures, and tested levels of accuracy, robustness, and cybersecurity.
  • Article 17 execution: document the aspects in paragraph 1(a)-(m), assign procedure owners and retain records for the current system version. Check EN 18286 Annex ZA conditions and separately assess paragraphs 2-4, which the standard does not cover.
Section 2

Document the system, data and logs

Start the technical file with the intended purpose and high-risk classification. Link each requirement to a design measure, test or procedure. Include the Annex IV material: system and development descriptions, data, monitoring, risks, validation, accuracy and robustness metrics, relevant discrimination testing, signed test logs, cybersecurity and monitoring after release.

Article 12 gives logging specific legal purposes. The system must technically allow automatic event recording over its lifetime, and the logs must be useful for identifying risk or substantial modification, supporting post-market monitoring, and enabling deployers to monitor operation under Article 26.

Providers and deployers should agree which logs are under each party's control, what retention rule applies, and how log access will work when a competent authority asks for evidence.

  • Technical documentation record: intended purpose, architecture, data sources, design choices, model or rules logic, validation approach, performance metrics, limitations, and foreseeable misuse.
  • Data-governance record: collection origin, annotation or labelling method, cleaning and updating steps, assumptions, suitability assessment, bias checks, data gaps, and corrective measures.
  • Test record: predefined metrics, probabilistic thresholds where used, validation and testing datasets, discriminatory-impact checks, signed test reports, and unresolved residual risks.
  • Log record: event types captured, start and end times where relevant, traceability purpose, access controls, retention period, escalation triggers, and authority-access procedure.
  • Change record: approved modifications, performance changes, post-market findings, provider corrective actions, and whether a new conformity assessment is needed.
Section 3

Provide instructions, oversight and safe operation

Write instructions that let deployers operate the system correctly. Article 13 requires provider identity, intended purpose, capabilities and limits, accuracy metrics, robustness and cybersecurity information, foreseeable risks, output interpretation, input requirements, oversight, maintenance and log collection.

Article 14 requires oversight by natural persons with enough information and control to monitor the system, understand limitations, avoid automation bias, interpret outputs, disregard or reverse outputs, and interrupt the system where appropriate.

Article 15 requires the system to perform consistently at an appropriate level of accuracy, robustness, and cybersecurity throughout its lifecycle and to be resilient against AI-specific attacks such as data poisoning, model poisoning, adversarial examples, model evasion, confidentiality attacks, and model flaws.

  • Transparency control: instructions name the intended purpose, expected user, limitations, input requirements, output interpretation guidance, maintenance needs, and log mechanisms.
  • Oversight control: each human reviewer has authority, training, escalation routes, override criteria, and a safe-stop or interruption procedure where appropriate.
  • Accuracy control: metrics are declared in the instructions for use, tested before release, monitored after deployment, and segmented where performance differs for relevant persons or groups.
  • Robustness control: failure modes, feedback loops, data drift, unexpected inputs, and interaction with other systems are tested and monitored.
  • Cybersecurity control: threat modelling covers training data, pre-trained components, prompts, interfaces, model access, logs, versioned APIs, and incident response.
Section 4

What deployers must do

If your organisation uses a high-risk system, follow the provider's instructions. Assign human oversight to people with the necessary competence, training, authority and support. Where you control input data, ensure it is relevant and sufficiently representative.

Deployers must monitor operation on the basis of the instructions for use. If use according to those instructions may result in a risk, the deployer must inform the provider or distributor and the relevant market surveillance authority without undue delay and suspend use.

If the deployer identifies a serious incident, it must immediately inform the provider first and then the importer or distributor and relevant market surveillance authorities. Deployers must also keep automatically generated logs under their control for an appropriate period, at least six months unless other Union or national law provides otherwise.

For financial institutions subject to Union financial-services governance requirements, Article 26(5) deems the monitoring obligation fulfilled through compliance with the relevant internal-governance arrangements, processes and mechanisms. Article 26(6) requires those institutions to maintain logs within their financial-services documentation.

Record the applicable regime and existing records rather than assuming the exception removes all deployer duties.

  • Before use: verify the provider instructions, oversight design, log access, registration status where applicable, and whether a data protection impact assessment (DPIA) or fundamental rights impact assessment (FRIA) is needed.
  • During use: monitor outputs, input-data quality, user complaints, incident signals, performance drift, and conditions that differ from the intended purpose.
  • For workplace use: employers must inform workers' representatives and affected workers before using a in the workplace.
  • For decisions about natural persons: deployers of relevant Annex III systems must inform natural persons that they are subject to use of the , subject to the law-enforcement rule referenced in Article 26.
  • For public authorities and EU bodies: check Article 49 registration obligations and do not use a system that should be registered but is missing from the EU database.
Section 5

Prepare the evidence for review

Give every requirement a named owner, legal reference, system-specific measure and evidence link. Assign a reviewer who can check whether the evidence still matches the deployed version.

For suppliers and companies integrating models, request system-specific evidence. Request instructions, performance metrics, oversight design, log format, monitoring contacts, incident routes and relevant technical-file extracts. For third-party tools, services, components or processes integrated into a high-risk system, agree in writing who provides the information and technical access needed.

What is the first AI Act requirements check for a ?

Confirm the high-risk classification and intended purpose, then map the system to Articles 8-15 before release and Article 16 provider duties. If the organization is deploying another provider's system, add Article 26 checks for instructions, human oversight, monitoring, input-data quality, logs, and incident escalation.

What evidence should a provider keep for AI Act high-risk AI requirements?

Keep technical documentation, data-governance records, risk management files, validation and testing reports, accuracy and robustness metrics, cybersecurity controls, instructions for use, quality management documentation, automatically generated logs under provider control, conformity assessment evidence, EU declaration of conformity, CE marking evidence where applicable, and registration evidence where Article 49 applies.

What evidence should a deployer keep under Article 26?

Keep the provider instructions, oversight assignments and training, input-data checks where the deployer controls input data, monitoring records, logs under deployer control for the required retention period, workplace or affected-person notices where applicable, registration checks for public-sector use, data protection impact assessment (DPIA) or fundamental rights impact assessment (FRIA) material where applicable, and incident notifications sent to the provider, distributor, importer, or authority.

  • Requirement matrix: Article 8-15 requirement, Article 16 provider duty, Article 26 deployer duty, owner, status, evidence link, and next review trigger.
  • Conformity file: technical documentation, quality management evidence, test reports, EU declaration of conformity, CE marking evidence where applicable, and Article 49 registration evidence where applicable.
  • Operating file: instructions for use, oversight roster, training records, input-data checks, monitoring dashboard, log retention settings, and incident escalation records.
  • Supplier file: contractual information rights, technical access, model or component change notifications, security testing evidence, vulnerability disclosure route, and support for deployer monitoring.
  • Exception file: unresolved limitations, residual risks judged acceptable, prohibited-use screening, suspension criteria, and corrective-action history.
Primary sources

References and citations

eur-lex.europa.eu6 citations
Referenced sections
  • Primary legal source for high-risk AI system requirements, provider obligations, deployer obligations, technical documentation, logs, transparency, human oversight, accuracy, robustness, and cybersecurity.
  • Supports the Article 8-16 high-risk AI requirements and provider obligations described in this section.
  • Supports the technical documentation, data governance, testing, logging, and retention evidence required for high-risk AI systems.
Show 3 more
  • Supports the transparency, human oversight, accuracy, robustness, and cybersecurity requirements in Articles 13-15.
  • Supports the Article 26 deployer duties for use according to instructions, human oversight, input data, monitoring, incident escalation, logs, workplace notice, registration, DPIA support, and notices to affected natural persons.
  • Supports the provider and deployer evidence pack across Articles 8-16, Article 26, Annex IV, conformity evidence, logging, and registration.
"High-risk AI systems shall comply with the requirements laid down in this Section"
More quoted passages
"The technical documentation shall be drawn up before that system is placed on the market"
"to interpret a system's output and use it appropriately"
"Deployers shall monitor the operation of the high-risk AI system"
"demonstrate the conformity of the high-risk AI system"
etsi.org3 citations
Referenced sections
  • Standards source used for practical cybersecurity evidence around AI-specific threats, secure development, testing, monitoring, documentation, and lifecycle controls.
  • Provides standards-based support for practical AI cybersecurity evidence, including threat modelling, AI-specific attacks, documentation, testing, and monitoring.
  • Supports practical cybersecurity evidence for supplier, testing, monitoring, documentation, and AI-specific threat controls.
"baseline security requirements for AI models and systems"
More quoted passages
"Document data, models and prompts"
"Monitor the system's behaviour"
digital-strategy.ec.europa.eu3 citations
Referenced sections
  • Commission overview summarising the risk-based framework and practical compliance steps for high-risk AI providers and deployers.
  • Commission overview confirming that high-risk AI providers need risk assessment, dataset quality, logging, documentation, human oversight, robustness, cybersecurity, accuracy, conformity assessment, registration, declaration of conformity, and CE marking.
  • Commission overview supporting the operational split between providers, deployers, authorities, post-market monitoring, and serious-incident reporting.
"The AI Act is the first-ever comprehensive legal framework on AI worldwide."
More quoted passages
"high level of robustness, cybersecurity and accuracy"
"deployers ensure human oversight and monitoring"
digital-strategy.ec.europa.eu2 citations
Referenced sections
  • Commission source for the harmonised-standard work areas connected to AI Act implementation, including risk management, data governance, record keeping, human oversight, accuracy, robustness, and cybersecurity.
  • Identifies Commission-requested harmonised-standard areas that align with the requirements evidence, including risk management, data governance, record keeping, human oversight, accuracy, robustness, and cybersecurity.
"European harmonised standards serve several crucial functions"
More quoted passages
"risk management"
eur-lex.europa.eu2 citations
Referenced sections
  • Binding amendment used for the revised high-risk dates, amended Article 111 transition rule, Article 6 safety-component clarifications, and Article 4a safeguards for special-category personal data.
  • Supports the revised Chapter III application dates, amended Article 111 transition rule, and Article 6 safety-component clarifications.
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