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EU AI Act Article 11: technical documentation for AI agents

Article 11 requires the technical documentation of a high-risk AI system to be drawn up before it is placed on the market or put into service, and kept up to date. Its content is listed in Annex IV. The documentation must demonstrate that the system complies with the high-risk requirements and give authorities the information they need to assess that. SMEs and start-ups may provide it in a simplified form.

What Annex IV covers, in short

• A general description: intended purpose, provider, versions, how the system interacts with hardware or software it is not part of.
• A detailed description of the elements and the development process: design choices, architecture, data, human oversight measures, validation and testing procedures with their metrics and results.
• Monitoring, functioning and control: capabilities and limitations, foreseeable unintended outcomes, and input data specifications.
• The risk management system (see Article 9).
• Relevant changes made over the lifecycle.
• The standards applied, the EU declaration of conformity, and the post-market monitoring plan (see Article 72).

Why agents drift out of their documentation

The document says the agent uses four tools and a specific model version. Six months later it uses seven tools, a newer model and a longer system prompt. Nobody lied; the documentation just stopped describing the system.

"Kept up to date" is the hard part, and it is easier if the system tells you what it actually does.

Let the run log feed the documentation

A complete run log answers several Annex IV questions with data instead of prose:

• Which models and versions were actually called, and since when.
• Which tools the agent used in production, not only which ones were planned.
• Which oversight measures fired: approvals requested, actions blocked, with the rule ids (see Article 14).
• Test results from recorded evaluation runs, with a behavioural diff between releases.

Keep the prose in the documentation and link each claim to a verifiable artefact. An auditor who can check one claim against a signed log tends to trust the rest.

Check your own logs

Paste a Vetro ledger or an OpenTelemetry GenAI trace export into the free checker: it verifies integrity and shows which record-keeping obligations your evidence covers, in your browser. When you need something to hand to an auditor or a customer, the countersigned EU AI Act report costs 49 USD, one-off: an ed25519 counter-signature over your evidence plus a mapping to the articles, including an explicit list of what the log cannot show.

See a sample ledger verified in one click, check your own logs free or get the countersigned EU AI Act report.