prEN 18229 parts 1 to 3: where the AI trustworthiness framework stands and what a test can use today
Category Standards
Published AIAssuranceLabs
The JTC 21 standards tracker recorded as the source of the three framework entries places part 1, logging, at enquiry, prEN 18229-1Enquiry, and parts 2 and 3, accuracy and robustness and transparency and human oversight, at drafting, prEN 18229-2Draft and prEN 18229-3Draft. None of the three parts is published, and none of the three is cited in the Official Journal. A provider cites a part as evidence for the method a test followed, at the stage shown, and the obligation it tests against stays the article text.
What the source says
The tracker lists the AI trustworthiness framework as one project in three parts, all drafted by working group 4, foundational and societal aspects, under the standardisation request the standards page shows as M/613. Part 1 covers Art. 12 record-keeping. Part 2 covers Art. 15 accuracy and robustness. Part 3 covers Art. 13 transparency and Art. 14 human oversight. Cybersecurity under Art. 15(5) sits outside the framework in a separate project, prEN 18282Enquiry, at enquiry.
The tracker defines the two stages that matter here. Enquiry is the open consultation in which national standards bodies and the public comment on a text; the text exists and can be read. Approval, or formal vote, is the stage at which national bodies vote on or ratify the finalised text. Drafting precedes both, and a document at drafting has no public text. The tracker records an availability target for part 1 and an evolving date for parts 2 and 3; the site holds neither date in data, so this post refers to the stage and not to a quarter.
| Part | Article | Stage | What a test can cite today |
|---|---|---|---|
prEN 18229-1Enquiry | Art. 12 | Enquiry | The enquiry text: expected event set, log fields, retention and traceability criteria |
prEN 18229-2Draft | Art. 15 | Draft | The drafting stage as the reference for metric categories, the declaration structure and perturbation classes; no public clause text |
prEN 18229-3Draft | Art. 13 and Art. 14 | Draft | Nothing beyond its scope; the categories a test covers come from Art. 13(3) and Art. 14(4) |
The difference between the rows is the difference between a clause and a scope. Part 1 at enquiry supplies clause-level content: the standards entry states that it gives a logging test its expected events and the fields each event carries. Part 2 at drafting supplies the categories its scope names, accuracy and robustness metric categories and the structure of the accuracy declaration for the instructions for use, and no clause a test can quote. Part 3 at drafting supplies only its title, and the standards entry records that no text is public.
What changes for a provider or deployer
Nothing in the four obligations moved. Art. 12(1) requires automatic recording of events over the lifetime of the system, Art. 13(3)(b)(ii) requires the declared level of accuracy, robustness and cybersecurity, Art. 14(4) requires the five oversight capabilities, and Art. 15(1) requires an appropriate level of accuracy, robustness and cybersecurity, all from the Annex III application date Deferred for a system classified under Art. 6(2). Art. 40(1) attaches a presumption of conformity only to a harmonised standard whose reference is cited in the Official Journal, and none is cited as of the anchor date
Verified on last full verification run, see the change log
. A draft or enquiry text is therefore evidence for the method chosen, and the Act sets no threshold in any of the four articles; the Art. 15 obligation page states the source hierarchy the provider justifies a target against.The protocols use each part at its stage. PR-12-LOG v1.0 cites the enquiry text of part 1 in four steps: the field list per expected event, the design review of the event catalogue, the completeness count per input and the retention observation. PR-15-ROB v1.0 cites part 2, draft, for the metric definition sheet, the held-out run and the perturbation classes, and takes the method categories and the formal-result format from two published documents, ISO/IEC TR 24029-1:2021Published and ISO/IEC 24029-2:2023Published, so that the statistical estimate and the formal result rest on a published clause. PR-14-OVR v1.0 names part 3, draft, with the note that its text is not public, takes the oversight capability categories from Art. 14(4) and the information categories from Art. 13(3)(b), and records each override, reversal and stop through the part 1 event set. The Art. 12 obligation page and the Art. 14 obligation page list the testable elements each protocol covers.
The robustness and adversarial testing and logging and human-oversight verification services run those protocols within the limits at what we cannot do. Each run produces a test report that names the criterion source per element, with the stage of every standard cited; a report that names part 2 names it as draft, and the declared level it verifies comes from the instructions for use under Art. 15(3); the draft supplies the declaration structure only. When a part advances, the report keeps the stage it was written against, and the protocol revision line records which stage a later run used.
What to do now
- Record the stage of each part in the Art. 17(1)(e) list of standards applied and in the Annex IV section 2(g) description of validation and testing procedures, as shown on the standards page.
- Fix the expected event set and the field list per event against the part 1 enquiry text, following the field-assignment step of PR-12-LOG v1.0, and keep the traceability rationale record under Art. 12(2).
- Define each accuracy and robustness metric with its formula, unit and test conditions, and record the provider's target justification, following the metric definition and target justification steps of PR-15-ROB v1.0.
- Take the oversight measure inventory from Art. 14(4)(a) to (e) and the two-person check under Art. 14(5), following PR-14-OVR v1.0, since part 3 has no text to take them from.
- Re-read the stage of each part on the standards page before each protocol run; a change from enquiry to approval changes the clause reference on the run record.
Related pages
The obligations, protocols, guides, services and hubs this post rests on.
- Guides
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