Technical documentation (Annex IV)
Mandatory provider documentation under Art. 11 of the EU AI Act
TL;DR
The technical documentation under Art. 11 and Annex IV of the EU AI Act is a comprehensive documentation obligation for providers of high-risk AI systems. Content: system description, development process, training data, risk management, human oversight, accuracy/robustness/cybersecurity, conformity assessment. Date of application for Annex III systems: 2 December 2027, for Annex I systems 2 August 2028 (Regulation (EU) 2026/1744 (Digital Omnibus AI), in force since 27 July 2026).
What is technical documentation (Annex IV)?
Annex IV requires 9 areas:
- General description of the AI system
- Development (methods, architecture, frameworks)
- Training data (origin, pre-processing, bias testing)
- Accuracy, robustness, cybersecurity
- Risk management system
- Human oversight
- Post-market monitoring plan
- Assessment of possible discrimination
- List of harmonised standards applied
Practical example
In practice: the technical documentation for an HR recruiting tool typically runs to 80-150 pages. Effort: 2-4 person-months on the provider's side.
Frequently asked questions
Is a GitHub README enough?
No. Annex IV technical documentation is considerably more comprehensive — risk management, bias testing and training-data documentation must be documented explicitly.
Do I have to make the documentation public?
No. It is submitted to the market surveillance authority on request. The EU database entry (Art. 49), by contrast, is public.
What is the difference from a DPIA?
A data protection impact assessment (DPIA, Art. 35 GDPR) assesses data protection risks. Annex IV technical documentation assesses the AI as a product — much broader.
See also
Practitioner note: This article is practice-oriented compliance documentation, not legal advice. We are compliance specialists, not a law firm. For legally binding advice, consult a qualified lawyer.