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EU AI Act Annex IV: what goes in the technical documentation
Annex IV lists the minimum content of the technical documentation that Article 11 requires a high-risk AI system's provider to draw up before it is placed on the market: a general description of the system and its intended purpose; a detailed description of its elements and development process, including design specifications and architecture; information on the data used to train, validate, and test it; a description of the human oversight measures under Article 14; an assessment of accuracy, robustness, and cybersecurity under Article 15; the computational resources used; a description of changes made through the system's lifecycle; the standards applied; a copy of the EU declaration of conformity; and a description of the system in place to monitor performance after deployment.
Who it applies to
Providers of high-risk AI systems under Annex III, and any distributor, importer, or deployer who becomes a provider by rebranding or substantially modifying a system under Article 25.
What evidence this implies
Two Annex IV items are effectively run-level evidence, not design documents: the description of changes over the system's lifecycle, and the description of the post-market monitoring system. Both require you to actually observe what the deployed system does, not just what it was designed to do.
Gaps to state honestly
Annex IV documentation describes the system as built and as intended to be monitored — it does not, by itself, prove the monitoring described is actually happening, or that no undocumented change slipped in. A file that says "logs are retained and reviewed" is a claim until something demonstrates it.
How Vetro helps
Vetro produces the verifiable trail that the lifecycle-changes and monitoring sections of Annex IV can point to: a hash-chained, ed25519-signed ledger of every model call, tool call, and policy decision, so "monitoring is in place" is backed by something checkable rather than asserted. Vetro Attest verifies a ledger or OTLP GenAI trace for free and, for 49 USD, issues a counter-signed report mapping that evidence to the EU AI Act, including what it cannot show. This is technical evidence, not legal advice.
Building the technical documentation file? Start your monitoring evidence at Vetro Attest, or check classification first with the high-risk classifier.
See a sample ledger verified in one click, check your own logs free or get the countersigned EU AI Act report.