Data Governance (Article 10 EU AI Act)
Training data quality obligation for high-risk AI
Practitioner's note: This article is practice-oriented compliance documentation, not legal advice. We are a compliance specialist, not a law firm. For legally binding information please consult a licensed lawyer.
TL;DR
Data governance covers all practices that ensure training data quality: source assessment, annotation, cleaning, bias detection, and documentation.
What is Data Governance under Article 10 EU AI Act?
Obligations under Article 10(2)-(5):
- Representative data selection for the intended purpose
- Bias examination
- Minimum data quality standards
- Pseudonymisation where possible
- Documentation of data provenance
Practical example
HR AI training on 50,000 application records: the bias test reveals an 8% preference for male candidates. Mitigation: re-balancing plus documentation.
Frequently asked questions
Special categories of data under Article 9?
Article 10(5) permits special categories for bias testing — subject to strict requirements.
Fine?
Article 99 — up to EUR 15 million / 3% for breaches.