Art. 11 and Annex IV: Technical documentation under the EU AI Act
Art. 11(1) requires the provider to draw up the technical documentation of a high-risk AI system before placing on the market or putting into service, and to keep it up to date. The documentation contains at least the elements in Annex IV sections 1 to 9. In this mapping, 12 elements are testable as consistency checks between declared values and evidence, 19 are documentation, and 4 are process. Regulation (EU) 2026/1744 moved the application date for Annex III systems (Deferred) and left the content of the obligation unchanged.
Where this applies
- DeferredAnnex III standalone high-risk obligations
- DeferredAnnex I product-embedded high-risk obligations
- In forceDigital Omnibus on AI, entry into force
What the text requires
Annex IV is the content list; Art. 11 sets when the documentation exists and what it demonstrates. A documentation element becomes testable where the text names a value or a fact that another artefact also records, such as a declared accuracy level in Annex IV section 3 and the test report in section 2(g).
| Requires | Testable | Documentation | Process |
|---|---|---|---|
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Metrics and where thresholds come from
Threshold sources, in order of precedence
- A harmonised standard cited in the Official Journal (none as of the anchor date)
- A JTC 21 draft standard (prEN), with its stage
- An ISO/IEC standard or technical report, with its stage
- A Commission guideline or code of practice, with its date from the standards data
- NIST AI RMF or a sector framework
- The state of the art, which the provider justifies and documents
Art. 11 and Annex IV set no numeric threshold. Annex IV section 2(g) and section 3 require the provider to state the metrics used and the degrees of accuracy; the values come from the provider's own testing under Art. 15. No harmonised standard is cited in the Official Journal of the European Union, so no presumption of conformity is available. The declaration structure today follows prEN 18229-2, a JTC 21 draft, which is hierarchy level 2. The provider justifies each declared value against the context of use and records that justification in the Annex IV section 4 statement on the appropriateness of the performance metrics; the PR-11-DOC consistency step that compares declared values with test reports records where each justification sits.
| Source and stage | Title | What it provides here | Verified on |
|---|---|---|---|
prEN 18229-2Draft | AI trustworthiness framework, part 2: accuracy and robustness | draft declaration structure for accuracy and robustness levels and their metric categories, which sets the form in which Annex IV section 2(g), section 3 and section 4 state the metrics and the declared values | Verified on kla.digital, JTC 21 Standards Tracker (updated 29 June 2026) |
prEN 18229-3Draft | AI trustworthiness framework, part 3: transparency and human oversight | draft requirements for the information a provider gives deployers under Art. 13 and for the human-oversight measures under Art. 14, which sets the expected content of the instructions for use in Annex IV section 1(h) and the oversight descriptions in section 2(e) and section 3; at drafting stage, no text is public | Verified on kla.digital, JTC 21 standards tracker (29 June 2026) |
prEN 18286Published | Quality management system for EU AI Act regulatory purposes (approved as EN 18286:2026) | the records, procedures and lifecycle controls of an Art. 17 quality management system, which give the documentation control, change recording and record-signing routines that keep the Annex IV set up to date under Art. 11(1) and section 6 | Verified on CEN-CENELEC, EN in the spotlight: AI quality management (31 July 2026) |
Procedures
Each protocol is versioned; its page states the derivation from the standards above. PR-11-DOC v1.0 assembles the set against the Annex IV headings and compares each declared value with the test report that supports it.
- PR-11-DOC v1.0Annex IV documentation assembly and consistency protocolv1.0
What an assessor asks for
- Annex IV technical documentation set (Annex IV sections 1 to 9)
- Annex IV gap and consistency report (PR-11-DOC output)
- Declared metric to test report consistency table (PR-11-DOC output)
- Version and architecture reconciliation record (PR-11-DOC output)
- Dated and signed test reports and test logs (Annex IV section 2(g))
- Lifecycle change record (Annex IV section 6)
- Standards and specifications list with requirement mapping (Annex IV section 7)
- Simplified technical documentation form (Art. 11(1) third subparagraph)
Common findings
- Accuracy is declared in the documentation as a single number while the test report gives a range under stated test conditions
- The system version in the general description differs from the version in the test reports and from the deployed build
- The architecture description reflects the design at project start and omits components and integrations added later
- Test reports carry no date or signature, so the documentation cannot show which version the tests covered
- The standards list names draft standards without their stage and without the requirement each one addresses
- The lifecycle change record stops at the first release and does not cover retraining or configuration changes
Questions
What is Annex IV of the EU AI Act?
Annex IV lists the minimum content of the technical documentation that Art. 11(1) requires for a high-risk AI system. It has nine sections. Section 1 is a general description of the system. Section 2 is a detailed description of the elements and the development process. Section 3 covers monitoring, functioning and control. Section 4 describes the appropriateness of the performance metrics. Section 5 describes the risk management system under Art. 9. Section 6 records relevant changes through the lifecycle. Section 7 lists the standards and specifications applied. Section 8 is a copy of the EU declaration of conformity under Art. 47. Section 9 describes the post-market monitoring system under Art. 72.
What are the EU AI Act technical documentation requirements?
Art. 11(1) requires the provider to draw up the technical documentation before the system is placed on the market or put into service. Art. 11(1) requires the provider to keep it up to date. The documentation demonstrates that the system meets the requirements of Chapter III Section 2. It contains at least the elements in Annex IV. Art. 11(2) requires a single documentation set for a system related to an Annex I Section A product. SMEs, start-ups and SMCs may use the Commission's simplified form under Art. 11(1).
What does Article 11 of the AI Act require?
Art. 11 requires technical documentation for every high-risk AI system. The documentation exists before placing on the market or putting into service. The provider keeps it up to date. Its minimum content is set in Annex IV. National competent authorities and notified bodies use it to assess the system against Chapter III Section 2. Art. 11(3) lets the Commission amend Annex IV by delegated act under Art. 97.
What connects to Article 11 of the AI Act?
Annex IV sets the content of the Art. 11 documentation. Annex IV section 2(e) and section 3 draw on Art. 13 and Art. 14 for the instructions for use and the human oversight measures. Annex IV section 2(g) and section 3 draw on Art. 15 for the accuracy and robustness metrics. Annex IV section 5 draws on Art. 9 for the risk management system. Annex IV section 8 draws on Art. 47 for the EU declaration of conformity. Annex IV section 9 draws on Art. 72 for post-market monitoring. Art. 17(1)(k) places the record-keeping of the documentation inside the quality management system. Art. 18 requires the provider to keep the documentation at the disposal of the national competent authorities.
Is there an Annex IV technical documentation template?
Annex IV itself is the template: it fixes the sections and the sub-points the documentation must contain. No harmonised standard for documentation structure is cited in the Official Journal. prEN 18229-2, a draft, gives a structure for declaring accuracy and robustness levels that fits Annex IV section 2(g). Art. 11(1) provides a simplified form, established by the Commission, for SMEs, start-ups and SMCs. PR-11-DOC assembles the documentation against the Annex IV headings and checks each declared value against its test report.
What do Articles 11 and 12 of the EU AI Act require together?
Art. 11 requires the technical documentation that describes the system. Art. 12 requires the system to record events automatically over its lifetime. Annex IV section 3 describes the monitoring, functioning and control of the system, which includes the logging design. Annex IV section 2(g) includes the test logs from validation and testing. Art. 12 logs are operational records; Annex IV test logs are development records. Both must name the same system version.
How we test this
We review the technical documentation against the Annex IV headings and verify that each declared metric, version, architecture element and oversight measure matches the test reports, the deployed artefact and the instructions for use. We document each gap and each inconsistency with its Annex IV section reference.
- Technical documentation and evidence-pack preparationPR-11-DOC
- Pre-conformity mock assessmentPR-43-MOCK
What we cannot do
- We do not perform conformity assessments where a notified body is required.
- We do not issue CE marking or the EU Declaration of Conformity.
- We are not a notified body.
- We do not give legal opinions on classification or liability.
- We test against requirements, prepare evidence, and structure documentation; compliance decisions remain with the provider or deployer, their notified body, and their counsel.