Technical documentation
What it means
What is technical documentation under the EU AI Act?
Technical documentation is the dossier a provider of a high-risk AI system must keep. It covers purpose, design logic, training data, performance metrics, risk process and monitoring plan. It has to be clear enough that a regulator can assess it without the original engineers in the room.
The EU AI Act sets the content directly in Annex IV, rather than leaving it to the provider's judgement. A national authority or notified body has to be able to assess it without relying on the provider's own explanation. Article 11 lets a small or micro enterprise use a simplified version of the same form, one the Commission publishes for that purpose.
Article 18 sets how long to keep it: ten years from when the provider places the system on the market or puts it into service. A national competent authority can request it at any point in that window. The same retention duty covers the quality management system records and the EU declaration of conformity too, not the technical documentation alone.
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In practice
Why it comes up
It is different from a marketing spec sheet or an engineering wiki page. A regulator or notified body wants the specific content the Act lists, not a general description of the product. It also comes up in procurement due diligence, where a buyer of a high-risk system sometimes asks to see excerpts before signing. A vendor who can produce none of it has told you something.
What to do about it
Start the document on the first day of build, recording design decisions as you make them. Reconstructing the reasoning behind a choice months later is far harder than writing it down at the time. Version it alongside the system itself, so the documentation for a given release actually matches what shipped. The AI Governance Starter Kit covers the register and policy this documentation builds on, ahead of the deeper regulatory detail.
Sources and neighbours
Sources
- Article 11 - Technical documentation
eur-lex.europa.eu
- Article 18 - Documentation Keeping
eur-lex.europa.eu
- NIST AI Risk Management Framework
nist.gov