What technical documentation does the EU AI Act require for high-risk AI systems?

Providers of high-risk AI systems must prepare technical documentation before the system is placed on the market, following the content set out in Annex IV, and keep it up to date. The documentation shows how the system meets the requirements for high-risk AI.

Article 11 requires providers to draw up technical documentation before a high-risk system goes to market, and to keep it current for the life of the system. Annex IV sets the minimum content: a general description of the system, its development process, data requirements, monitoring and control arrangements, performance metrics, the risk management system, a list of changes, and the EU declaration of conformity.

The documentation has to demonstrate compliance with the core requirements: data governance under Article 10, record-keeping under Article 12, transparency for deployers under Article 13, human oversight under Article 14, and accuracy, robustness, and cybersecurity under Article 15.

In practice, documentation fails when it is written after the fact or scattered across teams. Assign one owner for the file, tie each entry to a version of the system, and record the reasoning behind design decisions, because auditors test whether the evidence matches what the system actually does.

Day 3 of the course covers documentation, evidence, and record-keeping, including the human oversight and transparency requirements that the file must prove.

Expert Insight

Build the technical file alongside development rather than at the end. Assign one owner and tie each entry to a system version, so the evidence matches what is running in production.

“Build the technical file during development, then rebuilding it at audit time rarely matches what is running in production.”

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