Article 11: Technical Documentation
Article 11 requires providers to draw up technical documentation for each high-risk AI system before it is placed on the market or put into service, and to keep it up to date. The dossier must demonstrate compliance with Chapter III, Section 2 and give competent authorities and notified bodies the information they need to assess conformity—at minimum the elements in Annex IV. SMEs (including start-ups) may use a Commission simplified form once established; notified bodies must accept it for conformity assessment when used. Article 11(2) requires a single set of technical documentation where the system relates to a product under Annex I Section A Union harmonisation legislation. Article 11(3) empowers the Commission to adopt delegated acts under Article 97 to amend Annex IV in light of technical progress.
Who does this apply to?
- -Providers of high-risk AI systems under Article 6
- -Quality, regulatory, and engineering teams assembling Annex IV evidence packs
- -Notified bodies reviewing technical files during conformity assessment
Scenarios
A startup ships an Annex III HR tool with marketing PDFs but no system architecture, data lineage, or test metrics mapped to Annex IV headings.
Each release tag bundles a versioned Annex IV pack stored with the model hash and SBOM.
A medical device AI is also subject to MDR; the provider maintains one combined technical file under Article 11(2).
What Article 11 requires (in plain terms)
Before first supply, providers must compile technical documentation that:
- Proves the high-risk system meets Section 2 requirements (Articles 8–15 and annexes)
- Is clear and comprehensive for national authorities and notified bodies
- Includes at least everything listed in Annex IV (general description, design, monitoring, human oversight, testing, cybersecurity, etc.)
Documentation must be kept up to date when the system or its claims change (substantial modifications trigger broader Chapter III work—see Article 12 and conformity routes).
SME carve-path: the Act contemplates a simplified documentation form for SMEs including start-ups; until the Commission form exists and you opt in, treat Annex IV as the baseline for everyone proportionate to risk.
Language, format, and product-law bundles
Where a high-risk AI system relates to a product covered by Annex I Section A Union harmonisation legislation, Article 11(2) requires a single set of technical documentation containing both the AI Act information from paragraph 1 and the information required under the relevant sectoral legal acts—coordinate overlaps with your notified body early.
Article 11(3) empowers the Commission to adopt delegated acts under Article 97 to update Annex IV in light of technical progress, ensuring documentation requirements remain aligned with the state of the art.
How Article 11 connects to the rest of the Act
- Article 8 — Technical documentation is core evidence for Section 2 compliance.
- Articles 9–10 — Risk and data artefacts feed Annex IV sections.
- Article 12 — Logging design and IFU must align with what Annex IV promises.
- Article 13 — Instructions for use must be consistent with Annex IV and runtime behaviour.
- Article 14 — Oversight measures are documented in Annex IV and explained to deployers.
- Article 49 — Registration entries should trace to documentation versions.
- Article 72 — Post-market data closes the loop on documentation claims.
- Article 97 — Delegated acts may update Annex IV (Article 11(3)).
- Article 113 — Application dates.
Official wording: Article 11 — Technical documentation (English)
The following reproduces the complete text of Article 11 from the English consolidated text of Regulation (EU) 2024/1689 (OJ L 2024/1689).
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.
The 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.
2. 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.
3. 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.
Recitals (preamble) on EUR-Lex
The recitals in the same consolidated AI Act on EUR-Lex contextualise technical documentation, conformity assessment, and SME proportionality. Use the official preamble on EUR-Lex—do not rely on unofficial recital lists without checking sequence and wording against the authentic text.
Compliance checklist
- Own an Annex IV checklist with product, ML, security, and legal sign-off.
- Map each Annex IV item to concrete artefacts (diagrams, data cards, test reports, SBOMs, IFU drafts).
- Version documentation with each model/software release placed on the market.
- Cross-check Article 13 instructions and Article 12 logging design against Annex IV claims.
- Track Commission acts on the SME simplified form and Annex IV updates under Article 11(3).
Turn Annex IV into an actionable checklist—start the free assessment.
Start Free AssessmentRelated Articles
Article 6: Classification Rules for High-Risk Systems
Article 8: Compliance with the requirements
Article 9: Risk Management System
Article 10: Data and Data Governance
Article 12: Record-keeping
Article 13: Transparency and provision of information to deployers
Article 14: Human oversight
Article 15: Accuracy, robustness and cybersecurity
Annex IV: Technical Documentation for High-Risk AI Systems
Article 49: EU Database Registration
Article 72: Post-Market Monitoring
Article 97: Exercise of the Delegation
Article 113: Entry into Force and Application Dates
Related annexes
- Annex IV — Technical documentation
Frequently asked questions
Can documentation live only in GitHub?
Repositories can hold evidence, but you still need a curated, regulator-readable dossier that mirrors Annex IV headings and is version-controlled with each release.
Does Annex IV apply to every deployer tweak?
Deployers making substantial modifications may become providers under Article 25 and then inherit Article 11 duties for the modified system.
Is there a simplified documentation option for SMEs under Article 11?
The Commission may establish simplified forms of technical documentation for SMEs and start-ups. Until such forms are adopted, providers must follow the full Annex IV requirements but should document only elements proportionate to the size and nature of their organisation.