Technical documentation (AI Act)

What Annex IV requires

• A general description of the system: intended purpose, provider, versions, hardware, interaction with other systems, and the instructions for use.
• A detailed description of its elements and development: methods, design choices, system architecture, data requirements and datasheets for training data, human oversight measures, predetermined changes, validation and testing procedures and results.
• Information on monitoring, functioning and control, including capabilities, limitations and foreseeable unintended outcomes.
• The appropriateness of the performance metrics, the risk management system, relevant changes over the lifecycle, the harmonized standards applied, a copy of the EU declaration of conformity and the post-market monitoring plan.

How it applies

• Technical documentation practice: Annex IV reads like a documentation plan. Structured, modular authoring — topics per system component, reused across versions — makes it maintainable over the lifecycle. The documentation must be kept for ten years after the system is placed on the market.
• Smaller companies: SMEs, including start-ups, may provide the elements of Annex IV in a simplified form; the Digital Omnibus on AI extended simplifications for smaller companies.
• Audience: Technical documentation is written for authorities and notified bodies, not for users. User-facing information belongs in the instructions for use.

Compared with the USA, Canada and China

The USA has no general duty; California's SB 53 requires large frontier developers to publish a framework and transparency reports — public documents rather than documentation for an authority. Canada's federal institutions document their systems in the Algorithmic Impact Assessment. In China, the algorithm filing and the security assessment for generative AI serve a similar purpose: the provider describes the algorithm, its data and its safeguards to the regulator.