Operational guidance, not legal advice. This page distills named public sources (regulator guidance and industry practice). It is not a legal determination, not a notification decision, and not a substitute for your counsel, insurer, or a retained DFIR firm. Verify applicability and current deadlines for your facts and jurisdiction.
What technical documentation does the EU AI Act require?
Updated
Article 11 of Regulation (EU) 2024/1689 is Annex IV for high-risk AI systems, only if Article 6 applies. Article 53(1)(a)–(b) is Annex XI and Annex XII for GPAI models. A model card is not Annex XI. Not legal advice. It does not determine that YOU have to produce those packs.
AI technical documentation requirements, last verified 9 September 2026 against Articles 11, 18, 53 and 113 and Annexes IV, XI and XII of Regulation (EU) 2024/1689 (OJ L 2024/1689, 12.7.2024). Annex IV is not Annex XI. Annex XI is not Annex XII. A model card is best-practice reporting, not those annexes. Commission AI Act pages and AI Office materials are Commission materials — guidance, not the regulation. Regulation (EU) 2026/1744 is an amending regulation. This page is not legal advice, not a filing, not a determination that YOU have to produce Annex IV or Annex XI/XII packs, and does not start a clock.
This is Annex IV versus Annex XI and Annex XII, not YOUR pack
Audience: an engineering lead, founder, or counsel walking Regulation (EU) 2024/1689 on technical documentation. This page is not legal advice. It does not start a clock. Reading it does not start a clock. Mapping a row is not a determination that the Act applies, that YOUR system is high-risk, that YOU are a GPAI provider, or that YOU must produce an Annex IV or Annex XI/XII pack. This page does not file with the AI Office.
The AI Act is Regulation (EU) 2024/1689 of 13 June 2024, OJ L 2024/1689, 12.7.2024. ELI: http://data.europa.eu/eli/reg/2024/1689/oj. Article 11 is the high-risk technical-documentation duty. Its minimum contents are Annex IV. Article 53(1)(a) is the GPAI technical-documentation duty. Its minimum contents are Annex XI, provided upon request to the AI Office and national competent authorities. Article 53(1)(b) is a different pack: information for downstream providers who intend to integrate the model, at a minimum Annex XII. They are not the same annex. The EU AI Act overview on this site is the pillar page. The GPAI-requirements guide on this site is the Article 53 baseline page. Last verified 9 September 2026. Not legal advice.
- Statute versus guidance versus best practice: Articles 11, 18, 53 and 113 and Annexes IV, XI and XII of 2024/1689 are legal requirements only if they apply. Commission AI Act pages and AI Office materials are Commission materials — guidance, not the regulation. Model cards (Mitchell et al., FAT* 2019; community templates) are best-practice reporting, not a legal substitute for those annexes. This page quotes which kind of text it is relying on.
- The requirements-in-force-2026 guide on this site is the Article 113 dates page. The GPAI-requirements guide on this site is the Article 53 baseline page. The GPAI-systemic-risk guide on this site is the Article 51–55 page. The provider-vs-deployer guide on this site is the Articles 3, 16, 25 and 26 page. The AI-governance-requirements guide on this site is the Articles 4, 14, 26 and ISO 42001 page. The AI-risk-management-requirements guide on this site is the Articles 9 and 55 page. The training-data-transparency guide on this site is the Article 53(1)(d) page. The copyright-policy guide on this site is the Article 53(1)(c) page. A dedicated evidence-retention-checklist and AI-audit-evidence guide is not on this site yet. Naming them is not a link.
- This page does not invent a 2 August 2026 start date for GPAI documentation. Article 53 sits in Chapter V. Article 113(b) applies Chapter V from 2 August 2025, with the exception of Article 101. GPAI documentation duties therefore apply from 2 August 2025 under Article 113(b), except Article 101. They did not start on 2 August 2026. Article 11 sits in Chapter III Section 2. Article 113(c) of 2024/1689 keeps Article 6(1) and the corresponding obligations — Annex I product-embedded high-risk — on 2 August 2027, not 2 August 2026. This page does not invent a 2 August 2026 date for Annex I. Those dates are not one number.
Annex IV is not Annex XI or Annex XII
Do not conflate them. Annex IV is the high-risk AI-system technical file under Article 11. Annex XI is the GPAI-model technical file under Article 53(1)(a), for the AI Office and national competent authorities upon request. Annex XII is the downstream-provider information pack under Article 53(1)(b). A high-risk AI system under Article 6 is not automatically a general-purpose AI model. A GPAI model is not automatically a high-risk AI system. Mapping a row is not a finding that any annex binds YOU. Last verified 9 September 2026. Not legal advice.
| Track | What the cited text is | Kind of text | Last verified |
|---|---|---|---|
| Article 11 and Annex IV — high-risk AI-system file | The technical documentation of a high-risk AI system shall be drawn up before that system is placed on the market or put into service and shall be kept up-to date. It shall contain, at a minimum, the elements set out in Annex IV. Legal requirement if Article 6 high-risk applies. This page does not find that YOUR system is high-risk and does not determine that YOU must produce an Annex IV pack. | Article 11 and Annex IV of 2024/1689. Legal requirement, only if it applies. Distinct from Annex XI and Annex XII. | 9 September 2026 |
| Article 53(1)(a) and Annex XI — GPAI file for authorities | Providers of general-purpose AI models shall draw up and keep up-to-date the technical documentation of the model, including its training and testing process and the results of its evaluation, which shall contain, at a minimum, the information set out in Annex XI for the purpose of providing it, upon request, to the AI Office and the national competent authorities. Legal requirement if YOU are a GPAI provider. In force 2 August 2025 via Article 113(b). This page does not determine that YOU are a GPAI provider. | Article 53(1)(a) and Annex XI of 2024/1689. Legal requirement, only if it applies. Distinct from Annex IV. This product does not produce Annex XI for you. | 9 September 2026 |
| Article 53(1)(b) and Annex XII — downstream-provider pack | Draw up, keep up-to-date and make available information and documentation to providers of AI systems who intend to integrate the general-purpose AI model into their AI systems. Without prejudice to IP and trade secrets, that information shall enable those providers to have a good understanding of the capabilities and limitations of the model and to comply with their obligations, and shall contain, at a minimum, the elements set out in Annex XII. Distinct from Annex XI. | Article 53(1)(b) and Annex XII of 2024/1689. Legal requirement, only if it applies. Distinct from Annex IV and from Annex XI. | 9 September 2026 |
| Article 6 versus Article 3(63) — different gates | Article 6 classifies high-risk AI systems (Annex I product-embedded under Article 6(1); Annex III use-cases under Article 6(2)). That classification is the gate for Article 11 and Annex IV. Article 3(63) defines a general-purpose AI model. That definition is the gate for Article 53 and Annexes XI and XII. They are not the same gate. | Articles 6 and 3(63) of 2024/1689. Legal requirements, only if they apply. This page does not classify YOUR system and does not determine that YOU are a GPAI provider. | 9 September 2026 |
What original Article 11 actually says
Last verified 9 September 2026 against Article 11 of Regulation (EU) 2024/1689 on EUR-Lex (OJ L 2024/1689, 12.7.2024). These are legal requirements of the original regulation, only if they apply. This page does not apply them to YOU. Not legal advice.
| Point | What the cited text says | Kind of text | Last verified |
|---|---|---|---|
| Article 11(1), first subparagraph | Authentic Article 11(1): The technical documentation of a high-risk AI system shall be drawn up before that system is placed on the market or put into service and shall be kept up-to date. | Article 11(1) of 2024/1689. Legal requirement, only if it applies. This page does not draw up YOUR file. | 9 September 2026 |
| Article 11(1), second subparagraph — Annex IV minimum and SME form | That technical documentation shall be drawn up in such a way as to demonstrate that the high-risk AI system complies with the requirements set out in this Section and to provide national competent authorities and notified bodies with the necessary information in a clear and comprehensive form to assess the compliance of the AI system with those requirements. It shall contain, at a minimum, the elements set out in Annex IV. SMEs, including start-ups, may provide the elements of the technical documentation specified in Annex IV in a simplified manner. To that end, the Commission shall establish a simplified technical documentation form targeted at the needs of small and microenterprises. Where an SME, including a start-up, opts to provide the information required in Annex IV in a simplified manner, it shall use the form referred to in this paragraph. Notified bodies shall accept the form for the purposes of the conformity assessment. | Article 11(1) of 2024/1689. Legal requirement, only if it applies. This page does not determine that the Commission form is available for YOU and does not fill it. A third-party blog template is not that form. | 9 September 2026 |
| Article 11(2) — single file with Annex I Section A product law | Where a high-risk AI system related to a product covered by the Union harmonisation legislation listed in Section A of Annex I is placed on the market or put into service, a single set of technical documentation shall be drawn up containing all the information set out in paragraph 1, as well as the information required under those legal acts. | Article 11(2) of 2024/1689. Legal requirement, only if it applies. This page does not merge YOUR product file. | 9 September 2026 |
| Article 11(3) — delegated power to amend Annex IV | The Commission is empowered to adopt delegated acts in accordance with Article 97 in order to amend Annex IV, where necessary, to ensure that, in light of technical progress, the technical documentation provides all the information necessary to assess the compliance of the system with the requirements set out in this Section. | Article 11(3) of 2024/1689. Legal requirement of the power. This page does not rewrite Annex IV. | 9 September 2026 |
| Article 18 — keep the Article 11 file | Article 18(1)(a): the provider shall, for a period ending 10 years after the high-risk AI system has been placed on the market or put into service, keep at the disposal of the national competent authorities the technical documentation referred to in Article 11. Article 16(d) points providers at the documentation referred to in Article 18. A dedicated evidence-retention-checklist guide is not on this site yet. Naming it is not a link. | Articles 16(d) and 18 of 2024/1689. Legal requirement, only if it applies. This page does not keep YOUR file. | 9 September 2026 |
Annex IV contents — high-risk systems, as written
Last verified 9 September 2026 against Annex IV of Regulation (EU) 2024/1689 on EUR-Lex (OJ L 2024/1689, 12.7.2024). The technical documentation referred to in Article 11(1) shall contain at least the following information, as applicable to the relevant AI system. These nine points are the binding minimum. This page does not invent extra points and does not drop points. Mapping a row is not a finding that Annex IV binds YOU. Not legal advice.
| Point | What the cited text says | Kind of text | Last verified |
|---|---|---|---|
| Annex IV(1) — general description | A general description of the AI system including: (a) its intended purpose, the name of the provider and the version of the system reflecting its relation to previous versions; (b) how the AI system interacts with, or can be used to interact with, hardware or software, including with other AI systems, that are not part of the AI system itself, where applicable; (c) the versions of relevant software or firmware, and any requirements related to version updates; (d) the description of all the forms in which the AI system is placed on the market or put into service, such as software packages embedded into hardware, downloads, or APIs; (e) the description of the hardware on which the AI system is intended to run; (f) where the AI system is a component of products, photographs or illustrations showing external features, the marking and internal layout of those products; (g) a basic description of the user-interface provided to the deployer; (h) instructions for use for the deployer, and a basic description of the user-interface provided to the deployer, where applicable. | Annex IV(1) of 2024/1689. Legal requirement, only if Article 11 applies. | 9 September 2026 |
| Annex IV(2) — elements and development process | A detailed description of the elements of the AI system and of the process for its development, including: (a) the methods and steps performed for the development of the AI system, including, where relevant, recourse to pre-trained systems or tools provided by third parties and how those were used, integrated or modified by the provider; (b) the design specifications of the system, namely the general logic of the AI system and of the algorithms; the key design choices including the rationale and assumptions made; the main classification choices; what the system is designed to optimise for, and the relevance of the different parameters; the description of the expected output and output quality; the decisions about any possible trade-off made regarding the technical solutions adopted to comply with Chapter III, Section 2; (c) the description of the system architecture explaining how software components build on or feed into each other and integrate into the overall processing; the computational resources used to develop, train, test and validate the AI system; (d) where relevant, the data requirements in terms of datasheets describing the training methodologies and techniques and the training data sets used, including a general description of these data sets, information about their provenance, scope and main characteristics; how the data was obtained and selected; labelling procedures; data cleaning methodologies; (e) assessment of the human oversight measures needed in accordance with Article 14, including an assessment of the technical measures needed to facilitate the interpretation of the outputs of AI systems by the deployers, in accordance with Article 13(3), point (d); (f) where applicable, a detailed description of pre-determined changes to the AI system and its performance, together with all the relevant information related to the technical solutions adopted to ensure continuous compliance with Chapter III, Section 2; (g) the validation and testing procedures used, including information about the validation and testing data used and their main characteristics; metrics used to measure accuracy, robustness and compliance with other relevant Chapter III, Section 2 requirements, as well as potentially discriminatory impacts; test logs and all test reports dated and signed by the responsible persons, including with regard to pre-determined changes as referred to under point (f); (h) cybersecurity measures put in place. | Annex IV(2) of 2024/1689. Legal requirement, only if Article 11 applies. This page does not write YOUR development file. | 9 September 2026 |
| Annex IV(3) — monitoring, functioning and control | Detailed information about the monitoring, functioning and control of the AI system, in particular with regard to: its capabilities and limitations in performance, including the degrees of accuracy for specific persons or groups of persons on which the system is intended to be used and the overall expected level of accuracy in relation to its intended purpose; the foreseeable unintended outcomes and sources of risks to health and safety, fundamental rights and discrimination in view of the intended purpose of the AI system; the human oversight measures needed in accordance with Article 14, including the technical measures put in place to facilitate the interpretation of the outputs of AI systems by the deployers; specifications on input data, as appropriate. | Annex IV(3) of 2024/1689. Legal requirement, only if Article 11 applies. | 9 September 2026 |
| Annex IV(4) — performance metrics | A description of the appropriateness of the performance metrics for the specific AI system. | Annex IV(4) of 2024/1689. Legal requirement, only if Article 11 applies. | 9 September 2026 |
| Annex IV(5) — Article 9 risk-management system | A detailed description of the risk management system in accordance with Article 9. The AI-risk-management-requirements guide on this site is the Articles 9 and 55 page. Mapping this row is not a finding that Article 9 binds YOU. | Annex IV(5) of 2024/1689. Legal requirement, only if Article 11 applies. Distinct from a model-card metrics section. | 9 September 2026 |
| Annex IV(6) — lifecycle changes | A description of relevant changes made by the provider to the system through its lifecycle. | Annex IV(6) of 2024/1689. Legal requirement, only if Article 11 applies. | 9 September 2026 |
| Annex IV(7) — harmonised standards or other solutions | A list of the harmonised standards applied in full or in part the references of which have been published in the Official Journal of the European Union; where no such harmonised standards have been applied, a detailed description of the solutions adopted to meet the requirements set out in Chapter III, Section 2, including a list of other relevant standards and technical specifications applied. | Annex IV(7) of 2024/1689. Legal requirement, only if Article 11 applies. An ISO 42001 certificate is not this list. | 9 September 2026 |
| Annex IV(8) — EU declaration of conformity | A copy of the EU declaration of conformity referred to in Article 47. | Annex IV(8) of 2024/1689. Legal requirement, only if Article 11 applies. This page does not draw up YOUR Article 47 declaration. A model card is not an EU declaration of conformity. | 9 September 2026 |
| Annex IV(9) — post-market monitoring | A detailed description of the system in place to evaluate the AI system performance in the post-market phase in accordance with Article 72, including the post-market monitoring plan referred to in Article 72(3). | Annex IV(9) of 2024/1689. Legal requirement, only if Article 11 applies. This page does not run YOUR Article 72 monitoring. | 9 September 2026 |
Annex XI and Annex XII contents — GPAI models, as written
Last verified 9 September 2026 against Annexes XI and XII of Regulation (EU) 2024/1689 on EUR-Lex (OJ L 2024/1689, 12.7.2024). Annex XI Section 1 is information to be provided by all providers of general-purpose AI models, as appropriate to the size and risk profile of the model. Annex XI Section 2 is additional information to be provided by providers of general-purpose AI models with systemic risk. Annex XII is the downstream-provider pack. This page does not invent contents. Mapping a row is not a finding that YOU are a GPAI provider. The GPAI-requirements guide on this site is the Article 53 baseline page. The GPAI-systemic-risk guide on this site is the Article 51–55 page. Not legal advice.
| Point | What the cited text says | Kind of text | Last verified |
|---|---|---|---|
| Annex XI Section 1(1) — general description, all GPAI providers | A general description of the general-purpose AI model including: (a) the tasks that the model is intended to perform and the type and nature of AI systems in which it can be integrated; (b) the acceptable use policies applicable; (c) the date of release and methods of distribution; (d) the architecture and number of parameters; (e) the modality (e.g. text, image) and format of inputs and outputs; (f) the licence. | Annex XI Section 1(1) of 2024/1689. Legal requirement, only if Article 53(1)(a) applies. This product does not produce Annex XI for you. | 9 September 2026 |
| Annex XI Section 1(2) — development process, all GPAI providers | A detailed description of the elements of the model referred to in point 1, and relevant information of the process for the development, including: (a) the technical means (e.g. instructions of use, infrastructure, tools) required for the general-purpose AI model to be integrated in AI systems; (b) the design specifications of the model and training process, including training methodologies and techniques, the key design choices including the rationale and assumptions made; what the model is designed to optimise for and the relevance of the different parameters, as applicable; (c) information on the data used for training, testing and validation, where applicable, including the type and provenance of data and curation methodologies (e.g. cleaning, filtering, etc.), the number of data points, their scope and main characteristics; how the data was obtained and selected as well as all other measures to detect the unsuitability of data sources and methods to detect identifiable biases, where applicable; (d) the computational resources used to train the model (e.g. number of floating point operations), training time, and other relevant details related to the training; (e) known or estimated energy consumption of the model. With regard to point (e), where the energy consumption of the model is unknown, the energy consumption may be based on information about computational resources used. | Annex XI Section 1(2) of 2024/1689. Legal requirement, only if Article 53(1)(a) applies. Article 53(5) empowers delegated acts to detail measurement and calculation methodologies for points 2(d) and 2(e). This product does not produce Annex XI for you. | 9 September 2026 |
| Annex XI Section 2 — extra for GPAI with systemic risk | Additional information to be provided by providers of general-purpose AI models with systemic risk: (1) a detailed description of the evaluation strategies, including evaluation results, on the basis of available public evaluation protocols and tools or otherwise of other evaluation methodologies. Evaluation strategies shall include evaluation criteria, metrics and the methodology on the identification of limitations. (2) Where applicable, a detailed description of the measures put in place for the purpose of conducting internal and/or external adversarial testing (e.g. red teaming), model adaptations, including alignment and fine-tuning. (3) Where applicable, a detailed description of the system architecture explaining how software components build or feed into each other and integrate into the overall processing. The GPAI-systemic-risk guide on this site is the Article 51–55 page. This page does not designate YOUR model. | Annex XI Section 2 of 2024/1689. Legal requirement, only if Article 51 systemic-risk applies. Distinct from Annex IV. This product does not produce Annex XI for you. | 9 September 2026 |
| Annex XII(1) — general description for downstream providers | A general description of the general-purpose AI model including: (a) the tasks that the model is intended to perform and the type and nature of AI systems into which it can be integrated; (b) the acceptable use policies applicable; (c) the date of release and methods of distribution; (d) how the model interacts, or can be used to interact, with hardware or software that is not part of the model itself, where applicable; (e) the versions of relevant software related to the use of the general-purpose AI model, where applicable; (f) the architecture and number of parameters; (g) the modality (e.g. text, image) and format of inputs and outputs; (h) the licence for the model. | Annex XII(1) of 2024/1689. Legal requirement, only if Article 53(1)(b) applies. Distinct from Annex XI. This product does not produce Annex XII for you. | 9 September 2026 |
| Annex XII(2) — development elements for downstream providers | A description of the elements of the model and of the process for its development, including: (a) the technical means (e.g. instructions for use, infrastructure, tools) required for the general-purpose AI model to be integrated into AI systems; (b) the modality (e.g. text, image, etc.) and format of the inputs and outputs and their maximum size (e.g. context window length, etc.); (c) information on the data used for training, testing and validation, where applicable, including the type and provenance of data and curation methodologies. | Annex XII(2) of 2024/1689. Legal requirement, only if Article 53(1)(b) applies. This is the downstream pack, not the Annex XI authority file. This product does not produce Annex XII for you. | 9 September 2026 |
| Article 53(2) — exception for points (a) and (b) only | The obligations set out in paragraph 1, points (a) and (b), shall not apply to providers of AI models that are released under an open-source licence that allows for the access, usage, modification, and distribution of the model, and whose parameters, including the weights, the information on the model architecture, and the information on model usage, are made publicly available. This exception shall not apply to general-purpose AI models with systemic risks. Points (c) and (d) — the copyright policy and the public training-content summary — are not in that exception. The training-data-transparency guide on this site is the Article 53(1)(d) page. The copyright-policy guide on this site is the Article 53(1)(c) page. This page does not qualify YOUR licence. | Article 53(2) of 2024/1689. Legal requirement of the exception, only if it applies. Counsel reads the authentic paragraph. | 9 September 2026 |
Article 113: GPAI docs are 2 August 2025; Annex I high-risk is 2 August 2027
Last verified 9 September 2026 against Article 113 of Regulation (EU) 2024/1689 on EUR-Lex (OJ L 2024/1689, 12.7.2024). Article 53 sits in Chapter V. Article 113(b): Chapter III Section 4, Chapter V, Chapter VII and Chapter XII and Article 78 shall apply from 2 August 2025, with the exception of Article 101. GPAI documentation duties in Article 53(1)(a) and (b) therefore apply from 2 August 2025 under Article 113(b), except Article 101. They did not start on 2 August 2026. This page does not invent a 2 August 2026 start date for GPAI.
Article 11 sits in Chapter III Section 2 (requirements for high-risk AI systems). The original Article 113 second paragraph applies the rest of the Regulation from 2 August 2026. Article 113(c) keeps Article 6(1) and the corresponding obligations — Annex I product-embedded high-risk — on 2 August 2027, not 2 August 2026. High-risk Annex IV duties did not start on 2 August 2026 for Annex I. This page does not invent a 2 August 2026 date for Annex I. Those dates are not one number.
Regulation (EU) 2026/1744 is an amending regulation. Counsel reads the authentic operative article of any amendment. This page does not apply 2026/1744 to YOU. It does not rewrite Article 113(b) for Chapter V in the original regulation, and it does not move original Article 113(c) Annex I off 2 August 2027. Not legal advice.
A model card is not Annex IV, Annex XI, or Annex XII
Mitchell, Wu, Zaldivar, Barnes, Vasserman, Hutchinson, Spitzer, Raji and Gebru, Model Cards for Model Reporting, FAT* 2019 (DOI 10.1145/3287560.3287596), is a research paper proposing a reporting practice: model details, intended use, factors, metrics, evaluation data, training data, quantitative analyses, ethical considerations, caveats and recommendations. Community templates that follow that paper, including widely used repository model-card templates, are the same kind of text: best-practice reporting. They are not Regulation (EU) 2024/1689. Last verified 9 September 2026. Not legal advice.
A completed model card can be useful evidence that some facts exist. It does not discharge Article 11. It does not discharge Article 53(1)(a). It does not discharge Article 53(1)(b). Annex IV requires, among other points, a copy of the EU declaration of conformity referred to in Article 47 and a detailed description of the Article 9 risk-management system and the Article 72 post-market monitoring plan. Those points are not a model-card section. Annex XI Section 1(2)(d)–(e) require computational resources used to train the model and known or estimated energy consumption. Those points are not discharged by a metrics table. Filling a model card is not a determination that Annex IV, Annex XI, or Annex XII is met.
| Text | What it is | What this page does not do |
|---|---|---|
| Annex IV of 2024/1689 | Legal requirement — nine-point high-risk technical file, only if Article 11 applies. Includes Article 47 EU declaration of conformity and Article 72 post-market monitoring plan. | Does not treat a model card as Annex IV. Does not determine that YOU must produce an Annex IV pack. |
| Annex XI of 2024/1689 | Legal requirement — GPAI technical file for the AI Office and national competent authorities upon request, only if Article 53(1)(a) applies. Section 2 adds extras if Article 51 systemic-risk applies. | Does not treat a model card as Annex XI. This product does not produce Annex XI for you. |
| Annex XII of 2024/1689 | Legal requirement — downstream-provider information pack, only if Article 53(1)(b) applies. | Does not treat a model card as Annex XII. This product does not produce Annex XII for you. |
| Mitchell et al., Model Cards for Model Reporting (FAT* 2019) | Best practice / research. A proposed reporting practice. Not the regulation. | Does not treat a completed model card as discharging Article 11 or Article 53(1)(a)–(b). |
| Community model-card templates | Best practice. Repository and vendor templates that follow the 2019 paper. Not the regulation. | Does not treat a template as the Commission SME form under Article 11(1), as Annex IV, as Annex XI, or as Annex XII. |
Legal requirement versus guidance versus ShipReady recommendation
The table below labels each text. Do not treat a model card as the annex, do not treat guidance as the article, and do not treat a product surface as a determination. Last verified 9 September 2026. Not legal advice.
| Text | What it is | What this page does not do |
|---|---|---|
| Regulation (EU) 2024/1689 Article 11 and Annex IV | Legal requirement — high-risk AI-system technical documentation, only if Article 6 high-risk applies. Article 11 sits in Chapter III Section 2. Annex I corresponding obligations on 2 August 2027 under Article 113(c). | Does not determine that YOU must produce an Annex IV pack. Does not invent a 2 August 2026 date for Annex I. Does not draw up YOUR file. |
| Regulation (EU) 2024/1689 Article 53(1)(a)–(b) and Annexes XI and XII | Legal requirement — GPAI technical documentation and downstream-provider information, only if YOU are a GPAI provider. In force 2 August 2025 under Article 113(b), except Article 101. Distinct from Annex IV. | Does not determine that YOU are a GPAI provider. Does not invent a 2 August 2026 start date for GPAI. This product does not produce Annex XI for you. |
| Regulation (EU) 2026/1744 — Digital Omnibus on AI | An amending regulation. Counsel reads the authentic operative article of any amendment. | Does not treat an amending-regulation recital as moving original Article 113(c) Annex I off 2 August 2027, or as rewriting Article 113(b) for Chapter V. |
| European Commission AI Act page and AI Office materials | Commission materials. Guidance, not the regulation. Article 11 says the Commission shall establish a simplified technical documentation form for SMEs including start-ups. | Does not treat a Commission page as rewriting Annex IV, Annex XI, or Annex XII. Does not treat a third-party blog template as that Commission form. |
| Mitchell et al. 2019 model cards / community templates | Best practice / research. Not a legal substitute for the annexes. | Does not treat a model card as discharging Article 11 or Article 53(1)(a)–(b). |
| This product's Annex IV scaffold | ShipReady recommendation: a scaffold populated only with facts the organisation recorded on the AI-governance surface, flagging parts still missing. Not a finished dossier. Not legal advice. | Does not produce Annex XI for you. Does not produce a finished Annex IV conformity dossier. Does not determine that YOU must produce Annex IV. A named human still owns the assessment. |
What to do now
As of last verification on 9 September 2026, Article 53 GPAI documentation duties have applied since 2 August 2025 under Article 113(b), except Article 101. High-risk Chapter III Section 2 duties, including Article 11, sit on the original 2 August 2026 residual, except Article 6(1) corresponding obligations on 2 August 2027 under Article 113(c). High-risk Annex IV duties did not start on 2 August 2026 for Annex I. The list below is operational preparation. It is not a determination that YOU must produce an Annex IV or Annex XI/XII pack. Walk it with counsel.
- Ask counsel whether Article 6 high-risk applies to YOUR system, and whether YOU are a GPAI provider under Articles 3(3) and 3(63). This page does not run those tests. Marking eu_ai_act in an obligation map is not that determination and is not a documentation-pack determination.
- If counsel finds a high-risk AI system, walk Article 11 and Annex IV as written. Do not treat a model card as Annex IV. This product's Annex IV scaffold is a scaffold of recorded facts, not a finished dossier, and is not a determination that YOU must produce Annex IV.
- If counsel finds YOU are a GPAI provider, walk Article 53(1)(a) Annex XI and Article 53(1)(b) Annex XII. Do not treat a model card as Annex XI. This product does not produce Annex XI for you. Do not date those duties from 2 August 2026. Article 113(b) is 2 August 2025. The GPAI-requirements guide on this site is the Article 53 baseline page.
- The EU AI Act overview on this site is the pillar page. The requirements-in-force-2026 guide on this site is the Article 113 dates page. The AI-risk-management-requirements guide on this site is the Articles 9 and 55 page. The training-data-transparency guide on this site is the Article 53(1)(d) page. The copyright-policy guide on this site is the Article 53(1)(c) page. A dedicated evidence-retention-checklist and AI-audit-evidence guide is not on this site yet. Naming them is not a link.
Checklist
This is a question list, not a determination that YOU must produce an Annex IV or Annex XI/XII pack, and not a filing. Walk it with counsel. The GPAI-requirements guide on this site is the Article 53 baseline page.
- Does the Act apply to YOU at all? Articles 2 and 3. This page does not run that test.
- Does Article 6 high-risk apply? Article 11 and Annex IV are legal requirements only if it does. This page does not classify YOUR system and does not determine that YOU must produce Annex IV.
- Are YOU a provider of a general-purpose AI model? Articles 3(3) and 3(63). Article 53(1)(a) Annex XI and Article 53(1)(b) Annex XII are legal requirements only if that applies. This page does not determine that YOU are a GPAI provider.
- If GPAI, which pack — Annex XI for authorities upon request, Annex XII for downstream providers, Annex XI Section 2 extras if Article 51 systemic-risk applies? This page does not pick YOUR pack.
- Does a model card discharge Annex IV or Annex XI? No. A model card is best-practice reporting, not those annexes.
- Did GPAI documentation duties start 2 August 2026? No. Article 113(b) is 2 August 2025, not 2026.
- Did Annex I high-risk documentation duties start 2 August 2026? No. Article 113(c) is 2 August 2027, not 2026.
- Document the assessment, including a not-required decision. This page does not keep YOUR file.
Where this shows up in ShipReady Metrics
The bundled framework key eu_ai_act is customer-visible. Its version label is Regulation (EU) 2024/1689 high-risk obligations (starter subset). It is not in INTERNAL_TESTER_ONLY_FRAMEWORKS. The control-set is a starter subset, illustrative, to be tailored by a compliance owner; not legal advice; not a conformity determination; not CE marking. Readiness is not compliance and not an EU-database registration.
If you already have a session: signed-in app → Compliance → AI governance holds the AI inventory and AI-governance posture. That surface can export an Annex IV technical-documentation scaffold populated only with facts the organisation recorded, flagging parts still missing. That scaffold is a scaffold to complete, not a finished Annex IV conformity dossier, not legal advice, and not a determination that YOU must produce Annex IV. It does not produce Annex XI. Marking in-scope is not a documentation-pack determination and not auto-filing. A named human still owns the assessment.
This product does not produce Annex XI technical documentation for you, does not produce Annex XII for you, does not draw up an Article 47 EU declaration of conformity, does not run Article 72 post-market monitoring, does not file with the AI Office, and does not issue certifications. The obligation map lists frameworks the organisation has marked in-scope, including eu_ai_act if that mark is set. Marking eu_ai_act in-scope is not a determination that you must produce Annex IV or Annex XI.
This page does not document a public demo URL. There is no public EU AI Act demo path. This product does not start a clock.
Primary sources (last verified 9 September 2026)
Every regulatory or guidance claim on this page is taken from one of these. If a later revision of a source changes the rule, the date above is how you can see we have not re-checked yet.
Regulation (EU) 2024/1689 of 13 June 2024 (Artificial Intelligence Act), Articles 11, 16, 18, 53 and 113 and Annexes IV, XI and XII, is a legal requirement only if it applies. Entry into force 1 August 2024. Article 113(a) 2 February 2025; Article 113(b) 2 August 2025; general application 2 August 2026; Article 113(c) Article 6(1) from 2 August 2027. Regulation (EU) 2026/1744 is an amending regulation. The European Commission's AI Act page is Commission material, not the regulation. Mitchell et al., Model Cards for Model Reporting, FAT* 2019, is best-practice research, not the regulation. These are not a complete world list. Not legal advice.
The EU AI Act overview on this site is the pillar page. The requirements-in-force-2026 guide on this site is the Article 113 dates page. The GPAI-requirements guide on this site is the Article 53 baseline page. The GPAI-systemic-risk guide on this site is the Article 51–55 page. The provider-vs-deployer guide on this site is the Articles 3, 16, 25 and 26 page. The AI-governance-requirements guide on this site is the Articles 4, 14, 26 and ISO 42001 page. The AI-risk-management-requirements guide on this site is the Articles 9 and 55 page. The EU AI Act framework guide on this site is the education page under frameworks. The training-data-transparency guide on this site is the Article 53(1)(d) page. The copyright-policy guide on this site is the Article 53(1)(c) page. A dedicated evidence-retention-checklist and AI-audit-evidence guide is not on this site yet. Naming them is not a link.
Frequently asked questions
Is this legal advice?
No. It is a dated map of technical-documentation duties distilled from Regulation (EU) 2024/1689 Articles 11 and 53 and Annexes IV, XI and XII, with model cards labelled as best-practice reporting, not the regulation. Whether those articles apply to YOU, and whether YOU must produce an Annex IV or Annex XI/XII pack, is a legal question for counsel on your facts. This page does not start a clock and does not file with the AI Office.
Does this page mean we must file Annex IV?
No. This page does not determine that YOU must produce or file an Annex IV pack. Mapping a row is not a finding that the Act applies, that YOUR system is high-risk under Article 6, or that Article 11 binds YOU. Counsel applies Article 11 and Annex IV to YOUR facts. Last verified 9 September 2026.
Does a model card discharge Annex XI?
No. A model card, including Mitchell et al., Model Cards for Model Reporting, FAT* 2019, and community templates that follow that paper, is best-practice reporting. Annex XI of Regulation (EU) 2024/1689 is a legal requirement, only if Article 53(1)(a) applies. Filling a model card is not a determination that Annex XI is met. This product does not produce Annex XI for you. Last verified 9 September 2026.
Did GPAI documentation duties start on 2 August 2026?
No. Article 113(b) of Regulation (EU) 2024/1689 applies Chapter V from 2 August 2025, with the exception of Article 101. Chapter V includes Article 53. That is not 2 August 2026. This page does not invent a 2 August 2026 start date for GPAI. Last verified 9 September 2026.
Did Annex I high-risk documentation duties start 2 August 2026?
No. Article 113(c) of Regulation (EU) 2024/1689 applies Article 6(1) and the corresponding obligations from 2 August 2027. That is the Annex I product-embedded high-risk date. It is not 2 August 2026. This page does not invent a 2 August 2026 date for Annex I. Last verified 9 September 2026.
Does marking eu_ai_act in-scope mean we must produce Annex IV?
No. Marking the bundled framework key eu_ai_act in-scope on the obligation map is not a determination that you must produce an Annex IV or Annex XI pack, is not a finding that Article 11 or Article 53 applies, and is not auto-filing. Counsel applies those articles to YOUR facts. A named human still owns the assessment.
Does ShipReady produce Annex XI for you?
No. This product does not produce Annex XI technical documentation for you and does not produce Annex XII. Signed-in app → Compliance → AI governance can export an Annex IV scaffold populated only with recorded facts, flagging parts still missing. That scaffold is not a finished Annex IV dossier and is not a determination that YOU must produce Annex IV. This product does not file with the AI Office. A named human still owns the assessment.
Published by ShipReady Metrics, an evidence-based technology and compliance intelligence platform. This guide is educational and vendor-neutral.