Art. 15: Accuracy, robustness and cybersecurity under the EU AI Act
Art. 15 requires the provider to design and develop a high-risk AI system so that it achieves an appropriate level of accuracy, robustness and cybersecurity. The system performs consistently in those respects throughout its lifecycle. The provider declares the accuracy levels and metrics in the instructions for use. In this mapping, seven elements are testable, six are documentation and four are process. Regulation (EU) 2026/1744 moved the Annex III application date Deferred and the Annex I date, and left the content unchanged.
Where this applies
- DeferredAnnex III standalone high-risk obligations
- DeferredAnnex I product-embedded high-risk obligations
What the text requires
The accuracy levels and metrics declared under Art. 15(3) are the same values the instructions for use carry under Art. 13(3). The testing data sets that produce the accuracy result meet the quality criteria of Art. 10. Testing under Art. 9(8) runs against prior defined metrics and probabilistic thresholds, and the accuracy metrics declared under Art. 15(3) belong to that set.
| 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 for accuracy, robustness or cybersecurity in Art. 15. Art. 15(1) requires an appropriate level, and Art. 15(3) requires the provider to declare the level and the metrics in the instructions for use. Art. 15(2) assigns benchmarks and measurement methodologies to the Commission, working with metrology and benchmarking authorities, and none is published as of the anchor date. No harmonised standard is cited in the Official Journal, so the first level of the source hierarchy is empty and no presumption of conformity exists. The level in use today is the JTC 21 draft standards: prEN 18229-2 at draft stage for accuracy and robustness, and prEN 18282 at enquiry stage for cybersecurity. Below them sit ISO/IEC TR 24029-1:2021 and ISO/IEC 24029-2:2023 for robustness methods, and NIST AI RMF 1.0 for metric selection rationale. None of these documents publishes a numeric threshold for a high-risk system; the provider justifies the target against the context of use. The acceptance-criteria step of PR-15-ROB records that justification with the metric definition, the test set and the measurement conditions.
| Source and stage | Title | What it provides here | Verified on |
|---|---|---|---|
prEN 18229-2Draft | AI trustworthiness framework, part 2: accuracy and robustness | accuracy and robustness metric categories, the structure of the accuracy declaration for the instructions for use, and the perturbation classes a robustness assessment covers | Verified on kla.digital, JTC 21 Standards Tracker (updated 29 June 2026) |
prEN 18282Enquiry | Cybersecurity for AI systems | the AI-specific threat list behind Art. 15(5) (data poisoning, model poisoning, model evasion, confidentiality attacks) and the specification of the measures a cybersecurity test checks | Verified on kla.digital, JTC 21 Standards Tracker (updated 29 June 2026) |
ISO/IEC TR 24029-1:2021Published | Assessment of the robustness of neural networks, overview | robustness assessment method categories (statistical, formal, empirical) and the terminology for stating a robustness property and its test | Verified on ISO catalogue, ISO/IEC TR 24029-1:2021 |
ISO/IEC 24029-2:2023Published | Robustness of neural networks, formal methods | the formal-method procedure for showing a robustness property over a bounded input region and the content of a formal robustness result report | Verified on ISO catalogue, ISO/IEC 24029-2:2023 |
NIST AI RMF 1.0Published | AI Risk Management Framework | Measure function: metric selection rationale, and the valid and reliable and secure and resilient characteristics used to structure Art. 15 evidence | Verified on NIST, AI Risk Management Framework |
Procedures
Each protocol is versioned; its page states the derivation from the standards above. PR-15-ROB v1.0 covers the seven testable elements, from held-out accuracy to the attack classes named in Art. 15(5).
- PR-15-ROB v1.0Robustness and adversarial testing protocolv1.0
What an assessor asks for
- Accuracy test report on held-out and distribution-shifted sets (PR-15-ROB output)
- Accuracy declaration in instructions for use (Art. 15(3) and Art. 13(3)(b)(ii))
- Robustness test report with perturbation, fault-injection and fail-safe results (PR-15-ROB output)
- Adversarial and cybersecurity test report covering the Art. 15(5) attack list (PR-15-ROB output)
- Feedback-loop mitigation test record for a continuously learning system (PR-15-ROB output)
- Validation and testing procedures description with metric definitions (Annex IV section 2(g))
- Cybersecurity measures description with the risk-appropriateness rationale (Annex IV section 2(h))
- Lifecycle performance monitoring record with re-test triggers
Common findings
- Accuracy is declared as a single number without the metric definition, the test set or the conditions under which it was measured
- The declared accuracy comes from the development validation set, and no held-out or distribution-shifted measurement exists
- Robustness is asserted from the model architecture, and no perturbation or fault-injection result is recorded
- The cybersecurity evidence covers the hosting platform and not the AI-specific attack classes named in Art. 15(5)
- A system that continues to learn has no test that feeds its own outputs back as inputs and measures the drift
- Performance is measured once before release, and no trigger re-runs the tests after a model, data or environment change
Questions
What does Article 15 of the AI Act require for accuracy, robustness and cybersecurity?
Art. 15(1) requires the provider to design and develop a high-risk AI system so that it achieves an appropriate level of accuracy, robustness and cybersecurity. The same paragraph requires consistent performance in those respects throughout the lifecycle. Art. 15(3) requires the accuracy levels and metrics to be declared in the instructions for use. Art. 15(4) requires resilience to errors, faults and inconsistencies, and control of feedback loops in systems that continue to learn. Art. 15(5) requires resilience against unauthorised attempts to alter use, outputs or performance, with measures against data poisoning, model poisoning, adversarial examples, confidentiality attacks and model flaws where appropriate. Regulation (EU) 2026/1744 did not change this text.
What is Article 15 of the EU AI Act?
Article 15 is the accuracy, robustness and cybersecurity requirement for high-risk AI systems in Chapter III, Section 2 of Regulation (EU) 2024/1689. It applies to providers of systems classified as high-risk under Art. 6 and Annex I or Annex III. It has five paragraphs. Paragraphs 1, 3, 4 and 5 place duties on the provider. Paragraph 2 asks the Commission to encourage benchmarks and measurement methodologies with metrology and benchmarking authorities. The application date follows the Annex III or Annex I entry on the regulation page.
How is Article 15 accuracy, robustness and cybersecurity testing carried out?
Accuracy is measured on a held-out set and a distribution-shifted set with the metrics declared under Art. 15(3). Robustness is measured under input perturbation, noise, malformed input and injected faults, using the statistical, formal and empirical method categories of ISO/IEC TR 24029-1:2021. Formal robustness properties follow the procedure in ISO/IEC 24029-2:2023. Cybersecurity is tested against each attack class in Art. 15(5), with the threat list in the draft prEN 18282 as the reference. A continuously learning system is tested by feeding its outputs back as inputs and measuring the drift under Art. 15(4). Every step is written in PR-15-ROB with its source clause.
Does AI Act Article 15 set a numeric accuracy threshold?
No. Art. 15(1) requires an appropriate level of accuracy and does not state a number. Art. 15(3) requires the provider to declare the level and the metrics in the instructions for use. Art. 15(2) assigns benchmarks and measurement methodologies to the Commission, and none is published as of the anchor date. No harmonised standard is cited in the Official Journal for Art. 15. The draft prEN 18229-2 supplies metric categories and the declaration structure, not a threshold. The provider sets the target from the context of use and records the justification, which the acceptance-criteria step of PR-15-ROB captures.
How we test this
We test high-risk AI systems against Art. 15(1), 15(4) and 15(5): accuracy on held-out and distribution-shifted sets with the declared metrics, robustness under input perturbation and injected faults, and resistance to each attack class in Art. 15(5). We prepare the test reports and the accuracy declaration an assessor asks for; the scope limits are stated on what we cannot do.
- Robustness and adversarial testingPR-15-ROB
- Pre-conformity mock assessmentPR-43-MOCK
- Regression testing after substantial modificationPR-15-ROB, PR-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.