Artificial Intelligence Policy Tracker
Legal requirement Technical documentation European Union Partially applicable

Draw up technical documentation before placing a high-risk system on the market

Download: JSON · MarkdownUnder EU AI Act, Article 11 and Annex IV

Pending review · linked to the official source, waiting for a reviewer to confirm it (a factual check against the official source, not a legal review or legal advice)
What this label means
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Pending review
— linked to the official source and in the queue for a reviewer to confirm.
Source-linked
— linked to the official source, not yet confirmed by a reviewer.
Verification policy and current standing · a factual check, not legal advice.
No change recorded as of 26 Sep 2026 · official source last checked
On this page 9 sections

In brief

Draw up technical documentation before placing a high-risk system on the market is a legal requirement under the EU AI Act in the European Union (Article 11 and Annex IV). Technical documentation must be drawn up before a high-risk system is placed on the market or put into service and kept up to date. It applies from 2 December 2027.

Instrument
EU AI Act
Jurisdiction
European Union
Nature
Legal requirement
Source reference
Article 11 and Annex IV
Applies from
2 December 2027
Who it binds
Provider / developer
Evidence examples
1
Framework mappings
ISO/IEC 42001:2023, NIST AI Risk Management Framework 1.0
Controls that meet it
2
Official source
Open official text
Verification
Pending review · source-linked

What does it require?

Technical documentation must be drawn up before a high-risk system is placed on the market or put into service and kept up to date. It must demonstrate compliance with the Section 2 requirements and contain at least the elements in Annex IV, including a general description, development process, monitoring and control, risk-management description, and the applied standards. SMEs may use a simplified form provided by the Commission.

Practical action

Maintain an Annex IV-structured technical file under version control.

Who does it apply to?

Providers of high-risk AI systems.

Applies from:

Which controls meet this duty?

Satisfies: the control, operated properly, does the work the duty asks for. Supports: it contributes but the duty needs more. Each control page lists every other duty it serves, so work done once can be counted once.

  • satisfiesProcessProduct or model owner · at launch and on material change
    Technical documentation, model cards and instructions for use

    Serves 14 recorded duties · evidence: Technical documentation file, Model card or deployer information pack, Instructions for use

    Versioned technical file structured to the required elements.

  • supportsProcessData governance lead · once per ai system
    Data governance and dataset documentation

    Serves 8 recorded duties · evidence: Dataset documentation sheet, Data quality and bias check report, Dataset approval for use

    Dataset sheets supply the data sections.

Templates that cover this duty

Generated from the records. Free · no account · links emailed to your work address. This duty is cited in each file with its source reference and a link back here.

All 10 templates that cover it →

What evidence would a reviewer expect?

Evidence examples
EvidenceTypeNotes
Annex IV technical filedocument

Framework mappings

Original editorial crosswalks. They cite clause numbers only and reproduce no standard text; confidence reflects how direct the mapping is.

See every European Union duty mapped this way →

Framework mappings table
FrameworkReferenceNoteConfidence
ISO/IEC 42001:2023Clause 7.5 Documented information; Annex A control on system documentationOriginal editorial mapping.high
NIST AI RMF 1.0GOVERN 1.4, MAP 3.xDocumentation practices.medium

Frequently asked questions

Is this a legal requirement?

Yes. It is a legal requirement under EU AI Act (Article 11 and Annex IV).

Who must comply with this obligation?

Providers of high-risk AI systems.

When does this obligation apply?

It applies from 2 December 2027.

What evidence shows compliance?

A reviewer would expect: Annex IV technical file.

Which frameworks map to this obligation?

It is mapped to ISO/IEC 42001:2023 Clause 7.5 Documented information; Annex A control on system documentation, NIST AI Risk Management Framework 1.0 GOVERN 1.4, MAP 3.x. These are editorial crosswalks with a stated confidence, not official mappings.

Which controls satisfy this obligation?

Data governance and dataset documentation; Technical documentation, model cards and instructions for use.

What should an organisation do in practice?

Maintain an Annex IV-structured technical file under version control.

Cite this record

AIPolicyTracker (2026). “Draw up technical documentation before placing a high-risk system on the market (EU AI Act)” [AIPT-OBL-0008, not yet verified]. https://aipolicytracker.org/id/AIPT-OBL-0008 (accessed 27 October 2026). Data licensed CC BY 4.0.

Permanent id AIPT-OBL-0008: it never changes or gets reused, and its address keeps working if this page moves.

Cite the official text alongside it: Regulation (EU) 2024/1689 of the European Parliament and of the Council of 13 June 2024 laying down harmonised rules on artificial intelligence, Official Journal of the European Union, https://eur-lex.europa.eu/eli/reg/2024/1689/oj.

BibTeX
@misc{aipolicytracker2026_drawuptechnicaldocumenta,
  author       = {{AIPolicyTracker}},
  title        = {{Draw up technical documentation before placing a high-risk system on the market (EU AI Act)}},
  year         = {2026},
  howpublished = {\url{https://aipolicytracker.org/obligations/eu-ai-act-technical-documentation}},
  url          = {https://aipolicytracker.org/obligations/eu-ai-act-technical-documentation},
  urldate      = {2026-10-27},
  note         = {Data licensed CC BY 4.0. Accessed 27 October 2026}
}

Change history

No change to this record's tracked fields has been recorded since 15 October 2026, when field-level history began.

Similar obligations in other instruments

Disclaimer: informational only, not legal advice. Verify every claim against the linked official sources and consult a qualified lawyer before acting.