Art. 13: Transparency and provision of information to deployers under the EU AI Act
Art. 13 requires the provider to design and develop the high-risk AI system so that deployers can interpret its output and use it appropriately, and to supply instructions for use with the minimum content listed in Art. 13(3)(a) to (f). In this mapping, five elements are testable, fourteen are documentation and three are process. Regulation (EU) 2026/1744 moved the application date for Annex III systems Deferred and left the text of Art. 13 unchanged.
Where this applies
- DeferredAnnex III standalone high-risk obligations
- DeferredAnnex I product-embedded high-risk obligations
What the text requires
The instructions for use carry the level of accuracy, robustness and cybersecurity declared under Art. 13(3)(b)(ii), which is the level tested under Art. 15. The human oversight measures in point (d) refer to Art. 14, and the log mechanisms in point (f) refer to Art. 12. Each testable element below is a check that a declared statement matches a recorded test result or a section of the Annex IV technical documentation.
| 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
Regulation (EU) 2024/1689 sets no numeric threshold in Art. 13. Art. 13(3)(b)(ii) requires the provider to declare the level of accuracy, robustness and cybersecurity against which the system was tested and validated; the Act does not state what that level has to be. No harmonised standard is cited in the Official Journal, so no presumption of conformity exists for this article. The hierarchy level in use today is a JTC 21 draft: prEN 18229-3 (draft, no public text) for the information a provider gives deployers, and prEN 18229-2 (draft) for the structure of the accuracy and robustness declaration. The provider sets the declared level, justifies it against the context of use, and records the justification. The PR-15-ROB test-plan step that fixes the metric, the test set and the acceptance criterion records that justification, and the PR-11-DOC consistency step checks the declaration in the instructions for use against the recorded result.
| Source and stage | Title | What it provides here | Verified on |
|---|---|---|---|
prEN 18229-3Draft | AI trustworthiness framework, part 3: transparency and human oversight | draft requirements for the content and form of the information a provider gives deployers under Art. 13; at drafting stage no text is public, so it fixes no acceptance criterion today | Verified on kla.digital, JTC 21 standards tracker (29 June 2026) |
prEN 18229-2Draft | AI trustworthiness framework, part 2: accuracy and robustness | draft structure for declaring accuracy and robustness levels with their metrics and test conditions, which the Art. 13(3)(b)(ii) declaration follows and a PR-15-ROB test verifies | Verified on kla.digital, JTC 21 Standards Tracker (updated 29 June 2026) |
Procedures
Each protocol is versioned; its page states the derivation from the standards above. PR-11-DOC v1.0 checks the instructions for use for completeness against Art. 13(3) and for consistency with the Annex IV technical documentation, and PR-15-ROB v1.0 verifies the level declared under Art. 13(3)(b)(ii).
- PR-11-DOC v1.0Annex IV documentation assembly and consistency protocolv1.0
- PR-15-ROB v1.0Robustness and adversarial testing protocolv1.0
What an assessor asks for
- Instructions for use (Art. 13(2))
- Accuracy, robustness and cybersecurity declaration in instructions for use (Art. 13(3)(b)(ii))
- Known and foreseeable circumstances register (Art. 13(3)(b)(ii) and (iii))
- Pre-determined changes statement (Art. 13(3)(c))
- Log collection, storage and interpretation mechanism description (Art. 13(3)(f))
- Instructions-for-use completeness checklist against Art. 13(3)(a) to (f) (PR-11-DOC output)
- Instructions-for-use to technical documentation consistency report (PR-11-DOC output)
- Declared-level verification test report (PR-15-ROB output)
Common findings
- Accuracy is declared as a single number without the metric definition, the test set or the conditions of use.
- Robustness and cybersecurity are named in the instructions for use without a level against which the system was tested.
- The intended purpose stated in the instructions for use is wider than the population and conditions the test data covers.
- Known and foreseeable circumstances that reduce performance are listed in the risk management file but not in the instructions for use.
- The human oversight section of the instructions for use describes the user interface and not the measures under Art. 14.
- The instructions for use describe the current version and carry no statement of pre-determined changes or of the maintenance frequency.
Questions
What does Article 13 of the AI Act require?
Art. 13(1) requires the provider to design and develop the high-risk AI system so that its operation is sufficiently transparent for deployers to interpret the output and use it appropriately. Art. 13(2) requires instructions for use that accompany the system in a digital format or otherwise. Art. 13(3) lists the minimum content of the instructions in points (a) to (f). Point (b)(ii) requires the declared level of accuracy, robustness and cybersecurity against which the system was tested under Art. 15. Regulation (EU) 2026/1744 did not change the text of Art. 13.
What does Article 13 transparency and provision of information to deployers cover?
Article 13 covers two things: the transparency of the system's operation under Art. 13(1) and the instructions for use under Art. 13(2) and (3). The instructions for use name the provider, state the intended purpose, declare the tested performance levels and the circumstances that affect them, and describe explanation capabilities, group-level performance and input data specifications under Art. 13(3)(b). The instructions also state pre-determined changes under Art. 13(3)(c), human oversight measures under Art. 13(3)(d), resources, lifetime and maintenance under Art. 13(3)(e), and the log mechanisms under Art. 13(3)(f). Art. 13 applies to Annex III systems from the Annex III application date and to Annex I systems from the Annex I application date.
Which parts of EU AI Act Article 13 can be tested?
The declared accuracy level under Art. 13(3)(b)(ii) can be tested against a held-out set under the declared conditions of use with PR-15-ROB. The declared robustness and cybersecurity levels can be tested with perturbation and adversarial tests under PR-15-ROB. The known and foreseeable circumstances under Art. 13(3)(b)(ii) and (iii) can be reproduced to check the declared effect on performance. Every other statement in the instructions for use can be checked for presence and for consistency with the Annex IV technical documentation under PR-11-DOC. The Act sets no numeric threshold for the declared level; prEN 18229-2 is a draft and prEN 18229-3 has no public text, so the provider justifies the level against the context of use.
How we test this
We verify the accuracy, robustness and cybersecurity level declared under Art. 13(3)(b)(ii) against a test result obtained under the declared conditions of use, and we check consistency between each statement in the instructions for use and the Annex IV technical documentation. The documentation service and the mock assessment prepare this evidence within the limits stated on what we cannot do.
- 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.