Annex IV template: technical documentation under Article 11 of the EU AI Act. Who draws it up, what goes in, and how to note AI help
Is there an official template for the Annex IV technical documentation? Not yet (checked on 26 October 2026). Article 11(1) of the EU AI Act sets what the documentation contains at a minimum: the elements in Annex IV. It sets no fixed format. Only for SMEs and small mid-cap enterprises does it announce a simplified form from the Commission.
Our free DOCX template follows the nine points of Annex IV. It exists in English, German, Italian and French. You download it without giving an e-mail address, and you may adapt it. This page explains who draws up the documentation, what goes in, and how to record AI components and AI help with the writing.
Download the template (DOCX)DOCX, no e-mail address needed. Free to use and adapt. Not legal advice.
The duty applies from 2 December 2027 to high-risk AI systems under Annex III. For systems under Annex I it applies from 2 August 2028 (Article 113, point (c)).
Quotes are from the English language version of Regulation (EU) 2024/1689, consolidated version as of 27 July 2026 (CELEX 02024R1689-20260727). That version includes the changes made by Regulation (EU) 2026/1744.
Technical documentation referred to in Article 11(1): what the EU AI Act requires
The documentation "shall be drawn up before that system is placed on the market or put into service and shall be kept up-to date".
It must show that the system meets the requirements of Chapter III, Section 2. It is written for the national competent authorities and the notified bodies.
The core sentence reads: "It shall contain, at a minimum, the elements set out in Annex IV." Annex IV asks for this information "as applicable to the relevant AI system".
Paragraph 2: is the system linked to a product under the Union harmonisation legislation in Annex I, Section A? Then you draw up one technical documentation. It holds the information of paragraph 1 and the information those legal acts require.
Paragraph 3: the Commission may amend Annex IV by delegated acts to keep it in line with technical progress (Article 97).
What Regulation (EU) 2026/1744 changed: Annex IV is unchanged. In Article 11(1) it added small mid-cap enterprises next to SMEs. The form is now aimed at SMEs, start-ups and small mid-caps. The 2024 text named small and microenterprises.
The nine points of Annex IV at a glance
Annex IV has nine points. The table names each point, what it covers and what you usually keep as evidence. The template has one section per point.
| Point | What it covers (shortened) | Typical evidence |
|---|---|---|
| 1. General description of the AI system | Intended purpose, provider, version, hardware, user interface, instructions for use | Product sheet, version list, instructions for use |
| 2. Detailed description of the elements and the development process | Methods, design choices, architecture, data, human oversight, testing, cybersecurity | Architecture diagram, data sheets, test reports dated and signed |
| 3. Monitoring, functioning and control | Capabilities and limits, accuracy for groups of persons, foreseeable risks, human oversight | Performance report, risk list |
| 4. Appropriateness of the performance metrics | Why these metrics fit this system | A short reason for each metric |
| 5. Risk management system under Article 9 | A detailed description of the system | Risk register, procedure |
| 6. Changes during the lifecycle | Relevant changes the provider made to the system | Change log |
| 7. Harmonised standards or other solutions | Standards applied; if none, a detailed description of the solutions | List of standards |
| 8. Copy of the EU declaration of conformity (Article 47) | The signed declaration | Declaration (PDF) |
| 9. Post-market performance evaluation (Article 72) | The post-market monitoring system, including the plan under Article 72(3) | Monitoring plan |
Each point with guidance and a worked example: our guide Annex IV technical documentation template.
Who must draw up the technical documentation?
The provider of the high-risk AI system. The provider does two things: it develops the system or has it developed. And it places the system on the market or puts it into service under its own name or trademark (Article 3, point 3).
Article 16 makes the provider ensure that its system meets the requirements of Chapter III, Section 2 (point (a)). It keeps the documentation referred to in Article 18 (point (d)). Article 18(1) sets the period: 10 years after the system was placed on the market or put into service.
A deployer that uses someone else's system does not draw up Annex IV documentation. The deployer uses an AI system under its authority (Article 3, point 4). Its duties are in Article 26.
Before placing the system on the market, an importer checks that "the provider has drawn up the technical documentation in accordance with Article 11 and Annex IV" (Article 23(1), point (b)).
When does a deployer become a provider? Under Article 25(1), a deployer, distributor, importer or other third party counts as the provider of a high-risk AI system if it:
- puts its name or trademark on a high-risk AI system already on the market or in service, "without prejudice to contractual arrangements stipulating that the obligations are otherwise allocated" (point (a));
- makes a substantial modification to such a system so that it remains high-risk (point (b));
- changes the intended purpose of an AI system so that it becomes high-risk (point (c)).
It is then subject to the provider obligations of Article 16, and so also responsible for the technical documentation.
The initial provider is then no longer the provider of that system. But it cooperates closely with the new provider (Article 25(2)). Since Regulation (EU) 2026/1744 the law lists what this includes in particular, where relevant:
- "making available of technical documentation sufficient to assess compliance with the requirements laid down in Article 16";
- informing the new provider about known limitations and failure modes;
- targeted technical access, including for testing and validation.
The exception in the last subparagraph: "This paragraph shall not apply in cases where the initial provider has clearly specified that its AI system is not to be changed into a high-risk AI system". It then does not have to cooperate with the new provider or hand over documentation. Check the contract and the instructions for use before you repurpose a system.
Template for documenting AI-relevant components
Many high-risk systems are built on third-party parts: a pre-trained model, a library, a cloud service. Annex IV, point 2(a), asks about "recourse to pre-trained systems or tools provided by third parties". It also asks "how those were used, integrated or modified by the provider".
| Component | What you document | Where the information comes from |
|---|---|---|
| Pre-trained model, including a general-purpose AI model | Name, version, supplier; your fine-tuning; known limits (point 2(a), point 3) | A general-purpose AI model provider must give you information and documentation. It includes at least the Annex XII elements (Article 53(1)(b)). Certain models released under a free and open-source licence, without systemic risk, are exempt (Article 53(2)). |
| Third-party training, validation or test data | Origin, scope, selection, labelling, cleaning (point 2(d)) | Data sheet or contract with the data supplier |
| Software libraries and tools | Version, role in the system, update needs (point 1(c), point 2(c)) | Your software bill of materials (SBOM) and version control |
| Cloud or API service | Form of delivery, interaction with other software (point 1(b), point 1(d)) | The supplier's contract and service description |
Article 25(4) asks for a written agreement with the third party that supplies the component. It sets the information, capabilities, technical access and other assistance you need for your obligations. It does not apply to tools, services, processes or components that third parties make public under a free and open-source licence. General-purpose AI models are not covered by this exception.
Example wording for point 2(a):
"The system uses the pre-trained language model [name, version] from [supplier]. The model was fine-tuned with [data set] for [task] (method: [method]). The model provider's documentation is attached as annex [no.]. Known limits of the base model are described in section 3."
What is the correct wording if AI techniques were used to write the technical documentation?
The EU AI Act prescribes no wording for this. It does not require a note that an AI tool helped with the writing.
The second subparagraph of Article 50(4) covers text "published with the purpose of informing the public on matters of public interest". The technical documentation goes to authorities and notified bodies. It is not published to inform the public.
What counts: the provider stays responsible for every sentence. The documentation must show that the system meets the requirements (Article 11(1)). Test reports must be "dated and signed by the responsible persons" (Annex IV, point 2(g)).
A short note in the revision history of the document is therefore good practice, not a duty. It shows who checked the content and when.
Example wording (voluntary, for the revision history):
"Parts of this document were drafted with the help of an AI tool ([name, version]). [Name, role] checked and approved all content on [date]. Measured values, test results and quotes come from the sources named, not from the AI tool."
Did you mean AI techniques inside the system itself? Then the description belongs in Annex IV, point 2: methods, design choices, architecture and data. The example wording in the components section above helps with that.
Simplified technical documentation for SMEs and small mid-cap enterprises
SMEs, including start-ups, and small mid-cap enterprises "may provide the elements of the technical documentation specified in Annex IV in a simplified manner" (Article 11(1)). The Commission establishes a simplified form for this.
If you choose the simplified way, you must use that form. Notified bodies accept it for the conformity assessment.
Status on 26 October 2026: the Commission has not yet published the form. We checked its Article 11 page on the AI Act Service Desk and its guidelines page for high-risk systems. The law sets no date for the form.
The law speaks of "the elements of the technical documentation specified in Annex IV", provided in a simplified manner. Until the form exists, Annex IV with its nine points is the only structure the law names.
Article 3, point 14b, defines small mid-cap enterprises by reference to Recommendation (EU) 2025/1099.
Keep it and keep it up to date
The provider keeps the technical documentation at the disposal of the national competent authorities for 10 years. The period starts when the system is placed on the market or put into service (Article 18(1), point (a)).
Annex IV, point 6, asks for a description of the relevant changes during the lifecycle. Point 9 asks for a description of the system that evaluates performance after placing on the market, including the plan under Article 72(3).
For that plan the Commission adopts guidance, "including a template", by 2 September 2027 (Article 72(3)).
Who supervises in Germany
The German act on AI market surveillance and innovation (KI-MIG) entered into force on 29 July 2026. It makes the Bundesnetzagentur the market surveillance authority, contact point and complaints office for the EU AI Act.
The Bundesnetzagentur's AI Service Desk gives guidance and an online tool for a first risk-class check. Its press release of 29 July 2026 does not mention a form for the technical documentation.
What to do now
- Check whether your system is high-risk. Our free self-assessment takes five minutes.
- Clarify your role: provider, deployer or both. Watch for the three cases of Article 25(1).
- List every third-party component and ask its supplier for the documentation.
- Download the template and fill in points 1 and 2 first. Record who checked each section.
How LandingRed helps
LandingRed drafts the Annex IV technical documentation from the details you record for each AI system in your inventory, point by point. You review and edit every draft. The result is a structured Annex IV file, not an official Commission form.
More: LandingRed for the EU AI Act and the free self-assessment.
Frequently asked questions
Is there an official template for the Annex IV technical documentation?
No, not as of 26 October 2026. The EU AI Act prescribes content, not a fixed format. For SMEs and small mid-cap enterprises, Article 11(1) announces a simplified form from the Commission. It has not been published yet.
Who must draw up the technical documentation under Article 11?
The provider of the high-risk AI system, before placing it on the market or putting it into service. A deployer using someone else's system becomes the provider only in one of the three cases of Article 25(1). Whoever develops a system, or has it developed, is also a provider. That holds when it is put into service under one's own name, also for own use (Article 3, points 3 and 11).
Do I have to say that AI helped write the documentation?
The EU AI Act does not require it. The provider stays responsible for the content. A voluntary note on who checked and approved the content is good practice.
Did Regulation (EU) 2026/1744 change Annex IV?
No. It added small mid-cap enterprises in Article 11(1). It also moved the dates: 2 December 2027 for Annex III, 2 August 2028 for Annex I.
How long must I keep the technical documentation?
For 10 years after the system was placed on the market or put into service (Article 18(1)). During that time you keep it at the disposal of the national competent authorities.
Related resources
- Annex IV technical documentation template: every point with guidance and a worked example
- Annex III and Annex IV: which systems are high-risk and what they must document
- Model documentation and data lineage: what Annex IV, point 2(d), asks for
- Continuous monitoring of AI systems: Article 72 and the monitoring plan
- Deployer checklist for high-risk AI: what the deployer does under Article 26
- LandingRed for the EU AI Act: inventory, classification, Annex IV documentation
This page gives information, not legal advice. The text quoted is Regulation (EU) 2024/1689 in its consolidated version of 27 July 2026 (CELEX 02024R1689-20260727). The status of the Commission form is as of 26 October 2026.
Not sure whether your system is high-risk? Take the free EU AI Act self-assessment. It takes five minutes and estimates your exposure and your obligations. Start the self-assessment.
Reviewed and published under the editorial responsibility of AB Corporate Advisory S.R.L.
Sources for this page
- 1.Regulation (EU) 2024/1689 (AI Act), consolidated text of 27 July 2026 · EUR-Lex, Publications Office of the European Union
- 2.Regulation (EU) 2026/1744 (Digital Omnibus on AI), Official Journal of 24 July 2026 · EUR-Lex, Publications Office of the European Union
- 3.Bundesnetzagentur übernimmt zentrale Rolle bei der Umsetzung der KI-Verordnung · Bundesnetzagentur (Pressemitteilung), 29 July 2026
- 4.EU AI Act – diese Automatisierungen werden zur Hochrisiko-KI · Computerwoche, Fabian Helfer, 31 July 2026
Every link was opened and its date read on 26 October 2026. Laws are cited in their official text.
LandingRed automates all of this
Stop managing compliance in spreadsheets. Classify, document, assess, and monitor your AI systems from one platform.