Technical documentation maintained per Annex IV
Description
Article 11 — Technical documentation drawn up before placement on the market; covers system description, intended purpose, technical specs, design choices, validation results.
⚠️ Risk Impact
Annex IV technical documentation is the auditor's evidence base. Without it, you cannot demonstrate compliance with Articles 9-17. Annex IV is structured — your documentation must match its structure.
🔍 How EchelonGraph Detects This
EchelonGraph's Tier 1 Cloud Scanner automatically checks for this condition across all connected cloud accounts. Violations are flagged as high-severity findings with remediation guidance.
🔧 Remediation
Maintain Annex IV-structured technical documentation per high-risk system: intended purpose, hardware requirements, software components, training methodology, validation results, post-market monitoring plan. Version with the model; retain 10 years post-market.
💀 Real-World Attack Scenario
An EU bank deployed a credit-scoring AI from a US vendor. When the ECB inquired, the bank requested Annex IV documentation from the vendor — the vendor had a technical document but it didn't match Annex IV's required structure. Translation + restructure took 4 months; the bank's compliance deadline slipped; the bank reduced future vendor purchase scope.
💰 Cost of Non-Compliance
Article 11 absence: up to €15M / 3% revenue. Deployer-level downstream impact: customer-trust loss, expanded vendor diligence, churn risk in EU markets.
📋 Audit Questions
- 1.Show me the Annex IV technical documentation for your top high-risk system.
- 2.Which Annex IV sections are most recently updated? Which are oldest?
- 3.How is the documentation versioned alongside the model?
- 4.Can a deployer in another EU country obtain this documentation in their language?
⚡ Common Pitfalls
- ⛔Authoring 'technical documentation' that doesn't follow Annex IV's structure — auditors expect Annex IV section numbers
- ⛔Translating only to English when the deployer needs other EU languages
- ⛔Not retaining documentation versions for the 10-year statutory period
📈 Business Value
Annex IV documentation is non-negotiable for EU market placement. Without it, you cannot legally sell a high-risk AI system in the EU.
⏱️ Effort Estimate
4-8 weeks initial authoring per high-risk system; ongoing maintenance
EchelonGraph generates Annex IV-structured documentation from live workload + training metadata
🔗 Cross-Framework References
Automate EU AI Act ART11-TECH-DOC compliance
EchelonGraph continuously monitors this control across all your cloud accounts.
Start Free →